Page 447 – RTO Insider

July 14, 2022

ISO-NE Says No Extra Winter Programs Make Sense this Year

Despite consternation over the state of New England’s grid in the winter, ISO-NE sees no viable option for an out-of-market solution it could enact this year, officials told a stakeholder committee this week.

After about a month of reviewing its options, during which the grid operator looked at reviving two previously enacted winter programs, the recommendation to take no action leaves the region hoping for a mild winter.

ISO-NE had considered bringing back the Winter Reliability Program or starting the Inventoried Energy Program a year early. (See ISO-NE Weighs Reviving Reliability Programs for this Winter). But its analysis found that both of those programs carried cons and costs that would outweigh their potential benefits, the RTO told the Markets Committee in New Hampshire this week.

“Neither [program] is expected to provide significant benefits under extreme weather conditions, as their incremental reliability benefits are minimal given prevailing market conditions,” ISO-NE said in its presentation to the MC.

The Winter Reliability Program, which compensates resources for their unused fuel at the end of winter, would cost an estimated $170 million, nearly seven times as much as it cost when it was last used in 2017-2018. That includes what the RTO called “speculative” benefits, because there are already strong incentives for generators to maintain oil inventory even without the program in place.

The Inventoried Energy Program, which compensates resources for up to three days of inventoried energy that can be converted to electricity, has been approved for the 2023-2025 winters but will have to be changed subject to a recent court ruling. (See Court Strikes a Blow to ISO-NE Winter Plan.) It would cost an estimated $157 million and also carries questionable benefits.

Stockpiling Fuel

So with those options off the table, ISO-NE is hoping that cold weather doesn’t strain the system. A mild winter, like last year’s, would be manageable for the grid operator to get through, with no capacity deficiencies or load-shed events, the officials said.

A moderate winter, like in 2017-2018, could cause ISO-NE to rely on capacity deficiency procedures, laid out in OP-4. An extreme case, with sustained cold weather, could lead to load shedding and rolling blackouts.

A key question is whether generators will have enough on-site fuel this winter. Currently, New England’s fuel oil inventory is about 81 million gallons, a third of its storage capacity, ISO-NE said. But generators are expected to replenish their stores up to about 110 million gallons, with many of them waiting until fall as prices are expected to decrease by then.

LNG availability is also expected to be about the same as recent years, ISO-NE said.

In the event of fuel shortages, ISO-NE said it has a few levers it can pull, including asking for waivers of the Jones Act, emissions rules and hours-of-service restrictions for drivers carrying fuel. It could also ask the government to activate military staff or equipment to help move fuel.

And, as has been heavily used in Texas this week, the grid operator could ask customers to help with emergency conservation measures.

Looking Forward

“Energy adequacy will continue to be a concern beyond this winter because of limited infrastructure and vulnerability to large source-loss contingencies, which short-term programs will not address,” ISO-NE said in its presentation.

FERC’s September forum in Vermont will continue to address those issues, helping to “better inform the future longer-term solution space,” the grid operator said.

Work is also underway on a study with the Electric Power Research Institute looking at the operational impacts of extreme weather.

July 13, 2022January 3, 2024

Wisconsin Court Undercuts Lawsuit in Cardinal-Hickory Creek Dispute

The Wisconsin Supreme Court last week ruled that a former state regulator’s encrypted messages with power line developers did not amount to a serious risk of bias during the controversial Cardinal-Hickory Creek line’s permitting process.

In a 4-3 opinion July 7, the court’s conservative majority undercut a lawsuit brought by conservation groups that challenged the line’s permitting process before regulators in 2019. The court ruled that former Wisconsin Public Service Commissioner Mike Huebsch does not have to testify or turn over his phone after he used a software app to exchange covert messages with an American Transmission Co. (ATC) employee and a former independent contractor for ITC Midwest.

ATC and ITC Midwest, the project’s co-owners, last year uncovered evidence of years’ worth of encrypted messages between Huebsch and their employees. As a result, the companies redid the project’s certificate of public convenience and necessity to avoid improprieties. (See Former Wis. Commissioner’s Texts Imperil Cardinal-Hickory Creek Line.)

The court kept its decision focused on Huebsch’s conduct and didn’t address the merits of the PSC’s unanimous approval of the $500 million, 101-mile, 345-kV Cardinal-Hickory Creek line. It said Huebsch didn’t violate the line’s opponents’ due process and rejected the conservation groups’ subpoena for an inspection of Huebsch’s cellphone.

The court also said a lower court erred when it rejected Huebsch’s motion to quash the subpoena. It remanded the case back to the Dane County Circuit Court.

Penning the majority’s opinion, Chief Justice Patience Roggensack said the Driftless Area Land Conservancy (DALC) “allegations of bias do not come close to the level of alleging a cognizable due process claim.” The high court described the accusations of bias against Huebsch as “meritless,” based on “absolutely no factual evidence” and “borderline frivolous.” It said that public servants are presumed impartial unless there’s solid evidence to the contrary.

Conservative justices also said that the nation needs strengthened interstate transmission and said Cardinal-Hickory Creek enjoys “widespread support from labor, industry, business groups, environmentalists, Republicans and Democrats.”

Howard Learner, executive director of the Environmental Law and Policy Center, represents conservation groups DALC and the Wisconsin Wildlife Federation in the fight against the line. He said he was disappointed that the state supreme court “overreached in holding that Wisconsin law prevents conservation and consumer groups from taking discovery into the hundreds of phone calls, secret text messages, lunches, dinners and golf dates between … Huebsch and senior executives for the transmission companies that proposed this costly high-voltage transmission line.”

“Allowing these kinds of improper communications without any recourse under state law undermines public confidence in the fairness and integrity of Wisconsin’s utility regulatory process,” he said in an emailed statement to RTO Insider.

Learner said he agreed with the court’s liberal minority and said the four conservative justices “bent the judicial rules to provide special treatment in protecting improper conduct by their political ally.”

The liberal justices wrote in a dissent that “if our government is truly one of laws and not men and women, then we cannot use extraordinary constitutional powers to carve out special treatment for ourselves and only persons like us.” They said the majority justices’ “indulgence in the excesses of judicial power is not grounded in law and serves only to deepen inequalities in our system of justice.”

ATC and ITC issued a statement saying they appreciated the Supreme Court’s “thoughtful decision.” They celebrated the end of a “contrived fishing expedition that the project’s opponents orchestrated against former Commissioner Huebsch.”

“With the case now remanded back to the Dane County Circuit Court, the co-owners look forward to successfully concluding the litigation on the merits of the Public Service Commission of Wisconsin’s September 2019 decision to approve the project,” ATC and ITC said in an emailed statement.

Huebsch’s attorney Ryan Walsh told Wisconsin Public Radio that the ruling makes clear that there “shouldn’t be fact-finding into the personal lives of judges and judicators without rock-solid evidence that something inappropriate has happened.” Walsh said the decision ended a yearslong “cloud” hanging over his client.

Learner pointed out that the line is still set to cut through a protected wildlife refuge. A federal judge earlier this year blocked construction of the line through Upper Mississippi River National Fish and Wildlife Refuge. (See Federal Judge: Tx Line Can’t Cross Wildlife Refuge.)

ATC and ITC are appealing that decision before an appeals panel this fall. In the meantime, the companies continue to clear-cut the original route up to the protected refuge area. ATC and ITC report that they have nearly completed a segment in Iowa and are continuing construction in western Wisconsin.

With the matter of Huebsch’s texts decided at the state level, the DALC vowed to continue the fight against the project at the federal level.

Learner said a “fair review of the evidence will show that there are better, more cost-effective, more environmentally sound, and more flexible alternatives for reliable clean energy in the Wisconsin Driftless Area.”

ATC and ITC estimate that 127 renewable generation projects comprising about 19 GW of capacity are currently dependent on the line’s completion.

“Utilities across our region are depending on the Cardinal-Hickory Creek project to facilitate the region’s transition away from fossil fuels and support decarbonization goals,” the companies said. “The critical role of this project in meeting the region’s energy needs compels the co-owners to ensure it is built for the benefit of electric consumers by the scheduled in-service date of December 2023.”

The Cardinal-Hickory Creek line is the last of MISO’s $6.7 billion, 17-project Multi-Value Project portfolio approved in 2011.

July 13, 2022January 31, 2024

NY Climate Council’s 1st Labor Rep Shares Priorities

Mario Cilento, president of the New York AFL-CIO, spoke Monday to the state’s Climate Action Council as a new member and the first member representing organized labor.

“This council has been working for two years without labor representation … and it is incumbent upon me to share labor’s unequivocal goal in this process, and that is simply this: to combat climate change while protecting workers,” Cilento said.

Gov. Kathy Hochul said in March that she planned to appoint a labor representative to the council and announced Cilento as its newest member in early May.

Cilento said the council’s work should ensure a commitment to workers “in the most concrete and enforceable terms” to ensure that new jobs created by the climate and energy transition are “good union jobs.” And any worker that loses a job from that transition, he said, must “promptly, if not immediately” be re-employed “at the same rate of pay or greater.”

He called for estimates on new job creation and job losses identified in the council’s draft scoping plan to be more specific. The council’s study of the jobs needed to counter climate change — with a focus on buildings, fuels, electricity, transportation and lands — found that through 2030, 21 subsectors will add 211,000 jobs, and seven subsectors will experience “displacement of 22,000 jobs.”

“The intangible nature of projected job creation is somewhat understandable, but job loss is fully and completely tangible, particularly to those who know that their livelihoods, their ability to support themselves and their families is at risk and most likely finite,” he said.

To better understand estimates for jobs created and lost, he said the council should ensure more detail is provided on rate of pay, benefits, work locations, skills, responsibilities, and the employers that will create and eliminate jobs. Of the 211,000 new jobs employers could create through 2030, the council’s study said half were identified in the buildings sector, while about half of the job losses were at conventional fueling stations.

All jobs data related to the transition also should be tracked and updated at least every six months, according to Cilento.

For those jobs that are created, he added, workers need “robust” organizing rights and protections.

“All projects moving forward should include language that specifically calls for labor peace and project labor agreements, prevailing rate, buy American, buy New York and worker training funding,” he said.

While the council’s Just Transition Working Group has addressed labor concerns for the draft scoping plan, Cilento said it is necessary to “build on that work with as specific and definitive measures as possible.”

“The labor movement intends to be a committed partner in this historic endeavor … and I do strongly believe that anticipating and addressing as many of [labor’s] concerns as possible during this process will increase the [Climate Leadership and Community Protection Act’s] likelihood of long-term success,” he said.

The council accepted public comments on its draft scoping plan through July 1 and will review comments this summer before proposing approaches to address them in the final scoping plan due in January.

July 13, 2022

Stakeholders Lob Capacity Accreditation Ideas at ISO-NE

As ISO-NE starts moving forward with its work to update resource capacity accreditation rules in New England, the region’s energy stakeholders are urging it to cast a wide net and not commit to an approach too soon.

The grid operator in the last few weeks has said it’s leaning toward a marginal approach to capacity accreditation, using a concept called Marginal Reliability Impact (MRI). That’s in contrast to an average approach that accredits resources based on their share of their class’s total reliability contribution. (See ISO-NE Starts its Capacity Accreditation Journey.)

At this week’s NEPOOL Markets Committee meeting, Advanced Energy Economy warned ISO-NE not to rush into a decision, highlighting challenges with the marginal approach and advocating for broader consideration.

“Marginal accreditation is a novel approach and presents potential challenges as a replacement to the current capacity accreditation regime,” AEE’s Caitlin Marquis said in a presentation to the committee.

Among those challenges: It could result in different compensation to resources that provide the same total reliability benefit to the system and be more sensitive to accurate modeling of the region’s resource mix.

Also, even though the marginal method is often cited as having clearer entry and exit signals for resources, Marquis said, accurate signals don’t always facilitate efficient decisions if they’re still highly variable.

“Average versus marginal is a significant decision that should not be rushed; before moving forward with marginal, we should fully consider challenges and address shortcomings,” Marquis said in her presentation.

That could include exploring alternative or hybrid approaches, she said.

Also at the meeting, Ben Griffiths of LS Power raised concerns about the ability of a marginal accreditation method, which is an effective load-carrying capability (ELCC) measurement, to accurately measure the contributions of thermal resources.

“Proposals to apply ELCC-like accreditation mechanisms to thermal resources can obscure economic choices and may solidify the status quo by muting price signals,” Griffiths said in his presentation.

ELCC works for variable renewables because their performance is mostly determined by factors outside their control, Griffiths said. That’s not the case for thermal resources, which are more governed by economic conditions and operational choices, he argued.

The “class-based ELCC/MRI approach necessarily lumps good and poor performers into one class, which reduces downside risk for poor performers, and limits accreditation value for good ones,” Griffiths said. A preferable approach would be to refine a unit-specific accreditation method like PJM’s unforced capacity, which he said is a “reasonable starting point.”

ISO-NE is still early in what will be a yearlong-plus process of developing an update to capacity accreditation.

At the meeting this week, the RTO’s Feng Zhao put forward new details about how its conceptual design for an MRI would work, with a promise of more design information to come in the next few months.

July 12, 2022

Ohio Consumers’ Counsel Asks for Independent Probe of AEP

The Ohio Consumers’ Counsel, the Ohio Poverty Law Center and Pro Seniors, a legal advocacy group representing the elderly, ratcheted up the pressure on the Public Utilities Commission of Ohio late Monday with a demand for an independent investigation of American Electric Power’s (NASDAQ:AEP) decision to cut power to poor Columbus neighborhoods on June 13. (See AEP Under Fire as Load Sheds Persist in Ohio.)

The three consumer groups filed a 42-page motion in a PUCO docket created in 2020 to revise the reliability performance standards of AEP Ohio. Despite announcing a review on June 15 of AEP Ohio’s decisions to power to certain neighborhoods, PUCO has not created a docket for an investigation, nor held any public hearings. “We will be communicating with Ohio’s utilities to do an after-action review and determine what steps can be taken to avoid future occurrences,” PUCO Chair Jenifer French said at the time.

AEP has said it cut power to stabilize its system after receiving warnings from PJM of instability because the storm appeared to have affected some high-voltage transmission lines.

PUCO has invited AEP executives and top members of PJM to address the issue after its regular meeting on Wednesday.

The groups’ motion argues:

“The PUCO should order an investigation of the AEP outages (as contrasted with its current ‘review’), hire an independent auditor, order local hearings and other opportunities for the public to be heard, and determine if AEP was negligent and thereby owes consumers compensation for perishable food and other damages. The PUCO should conduct an investigation, in this case that is related to AEP’s reliability, or initiate an investigation and find ‘reasonable grounds’ to hold a hearing.”

July 12, 2022October 26, 2023

Clean Hydrogen Interest Builds in New Mexico

Conversion of the Escalante Generating Station into a hydrogen-fueled power plant would help support continued decarbonization of New Mexico’s electric system, a project proponent told state lawmakers recently.

“When you’re adding solar and wind … you need other resources, other decarbonized resources and clean resources that can help balance that out,” said Justin Campbell, vice president of power and transmission for Tallgrass Energy. “You need that so that the grid is still reliable and power is still affordable. That’s the role that this facility can serve.”

Campbell spoke during a meeting last month of the New Mexico Legislative Finance Committee. The committee spent a half day discussing progress in the state’s efforts to develop a hydrogen economy.

Tallgrass has a majority stake in a company called Escalante H2 Power (EH2), which wants to convert the Escalante Generating Station into a hydrogen-fueled plant. Escalante’s operator, Tri-State Generation and Transmission Association, shut down the 253 MW coal-powered plant in 2020.

EH2 plans to produce hydrogen at the Escalante site through reformation of methane from natural gas. Campbell said 97% or more of the CO₂ produced in the process would be captured and stored, resulting in so-called blue hydrogen. The CO₂ will not be used for enhanced oil recovery, he added.

Escalante is expected to provide about 265 MW of dispatchable power from hydrogen. Campbell said the hydrogen could also potentially be used in industry or for long-haul trucking.

EH2 is still analyzing the market for clean hydrogen in New Mexico, studying geological CO₂ sequestration and looking for the best way to retrofit the Escalante facility, according to a report prepared for the Legislative Finance Committee by one of its analysts.

EH2 plans to eventually switch from blue hydrogen to green hydrogen, produced through the electrolysis of water using clean energy, the report said.

Hydrogen in Aviation

In addition to EH2, other hydrogen-focused businesses are setting up shop in New Mexico, said Alicia Keyes, cabinet secretary for the state’s Economic Development Department.

Universal Hydrogen, a company whose goal is to decarbonize aviation, announced in March that it would build a manufacturing hub in Albuquerque. One of the company’s projects is to develop powertrain conversion kits to allow existing regional turboprop aircraft to fly using hydrogen fuel.

BayoTech, a company that offers hydrogen production, transport, storage and fueling services, is headquartered in Albuquerque. The company’s model is to produce hydrogen at a smaller scale at local hydrogen hubs.

In December, the company announced an agreement to provide hydrogen to New Mexico Gas Co. from a hydrogen hub installed on the gas company’s property. In addition, BayoTech is working with San Juan College on a graduate-level program to train workers on hydrogen production systems.

“Obviously, what is going on here and with Escalante is going to be transformative for this area,” Keyes said.

Four-state Partnership

The business developments come as New Mexico is working with three other states — Colorado, Wyoming and Utah — to vie for a portion of $8 billion in federal hydrogen hub funding. (See Mountain States Partner to Secure Hydrogen Hub.)

Since the partnership was announced in February, the states have assembled an executive committee and working groups for the project and are developing a legal entity that would accept the funds if awarded, New Mexico State University Chancellor Dan Arvizu told the Legislative Finance Committee. New Mexico State is part of a team working on hydrogen hub strategies.

DOE last month released a notice of intent to issue a funding opportunity announcement (FOA) for hydrogen hub funding, with release of the FOA expected in September or October. (See DOE Hydrogen HUB Funding Program Announced.)

“There’s a lot of adjacent industries that will be enabled by having a hydrogen economy that’s robust in our state,” said Arvizu, who formerly headed the National Renewable Energy Laboratory.

Additional infrastructure will be needed, for transmission in particular, for the state to take full advantage of a hydrogen economy, Arvizu said.

Executive Order on Hydrogen

State officials are also working to meet directives of an executive order that Gov. Michelle Lujan Grisham issued in March to launch a clean hydrogen development initiative.

The order directs the Economic Development Department to include hydrogen in the state’s key economic sectors and “support the development of clean and zero-carbon hydrogen production.”

The order also directs the state’s Environment Department and the Energy, Minerals and Natural Resources Department (EMNRD) to craft a proposal for including zero-carbon hydrogen electric generation facilities in the definition of “zero-carbon resources” as used in state law. The proposal would then be considered by the New Mexico Public Regulation Commission.

In addition, the executive order instructs EMNRD to make recommendations on the development of carbon sequestration.

The departments will also provide recommendations to the governor before the 2023 legislative session on how to support a hydrogen industry in the state.

July 12, 2022January 31, 2024

Maine’s 2007 Ports Initiative Puts Sears Island OSW Plan in New Light

A 15-year-old consensus agreement for development on Maine’s Sears Island highlights potential challenges the Department of Transportation might face for its interest in building an offshore wind hub there.

The former Sears Island Planning Initiative steering committee executed an agreement in 2007 that said any future development in the Port of Searsport should consider Mack Point a priority location over the adjacent Sears Island.

MaineDOT, however, said last fall that, after evaluating four sites at the Port of Searsport, an undeveloped parcel on Sears Island would be its preferred location for an OSW marshalling and fabrication facility and a component staging area. The study also determined that Mack Point could provide support facilities for the Sears Island hub.

“The history and discussion of appropriate uses for the Port of Searsport, including Sears Island, have a long, detailed and potentially contentious history,” MaineDOT Commissioner Bruce Van Note told the recently established Maine OSW Port Advisory Group on Thursday.

MaineDOT established the 19-member advisory group in March to advise the department on port facility planning and development. The advisory group functions as a companion effort to Maine’s OSW roadmap initiative, which includes a working group that is making recommendations for port development.

At the time the Sears Island consensus agreement was signed, OSW was not on the horizon for Maine, but similar activities, such as a marine cargo or container port, were considered viable for the island’s western shore.

MaineDOT “concluded that a … marshalling port facility to support offshore wind does meet the requirements of acceptable uses on Sears Island” as set out in the agreement, Van Note said.

The Maine Department of Transportation’s proposed location on Sears Island for the Searsport Offshore Wind Hub. | Maine Department of Transportation

Steve Miller, speaking on behalf of the Islesboro Islands Trust, disagreed with Van Note during the meeting, saying that identifying Sears Island as the preferred alternative for the OSW hub goes against the planning initiative’s intentions.

“I think it makes sense to give preference to Mack Point, thoroughly exhaust those kinds of possibilities there … and if it’s necessary in a deeper application or in any other way, to then explore the possibility of other sites,” Miller said.

Language in the agreement relating to what is acceptable for development on Sears Island raises certain questions, according to Miller. For example, he said that the agreement allows “compatibly managed marine transportation, recreation, education and conservation” as appropriate uses for the island, but it offers no definition of “compatible.”

While Miller was uncertain whether the consensus agreement is legally binding, he said it represents an opportunity for the state’s institutions to build trust with residents.

“The constituents that I represent are eager to see this offshore wind initiative get legs in the right time at the right place, but there’s very, very deep concern about the negative impacts to Sears Island and Upper Penobscot Bay,” he said.

Conservation

While the Sears Island Planning Initiative set out to determine the best use of the island, the resulting consensus agreement did nothing to solve the Sears Island “saga,” David Gelinas, a Penobscot Bay pilot and steering committee member, said during the meeting. Instead, it “kicked the can down the road 15 years” by calling for the permanent conservation of two-thirds of the island without setting a clear plan for MaineDOT’s development of the remaining one-third.

Former Gov. John Baldacci signed an executive order in 2009 directing MaineDOT to grant a conservation easement for 600 acres of the island, as recommended by the steering committee. The state did not, however, make the conservation “contingent upon getting the necessary permits that would allow the remaining 330 acres ever to be used for marine transportation, which is why we’re here now,” Gelinas said.

The island, he added, can host a variety of uses.

“I wholeheartedly embrace the concept of conservation and recreation uses coexisting with a marine transportation facility on Sears Island,” he said.

The advisory group will meet again in September to consider the state’s proposed purpose and need for an OSW hub and the reasonableness of proposed alternatives for the project.

July 12, 2022

SPP Extends Record for Peak Demand

WESTMINSTER, Colo. — SPP set a new mark for peak demand Monday, wiping out a record that was less than a week old.

The grid operator’s 14-state footprint met 51.4 GW of demand at 4:44 p.m. CT. That betters the previous mark of 51.1 GW set July 5. (See SPP Sets Demand Record amid Midwest Heat.)

The new mark is expected to be as equally short-lived as the previous record. Staff are projecting demand will hit 53 GW next Monday, when forecasters are expecting triple-digit temperatures and muggy weather as a high-pressure ridge moves from the Rockies to the Plains.

“Summer’s not over,” Bruce Rew, senior vice president of operations, told the Markets and Operations Policy Committee meeting Tuesday.

Rew said SPP would remain in a resource advisory until at least Wednesday, “if not longer.” On Wednesday, the RTO extended the advisory for its entire 14-state balancing authority to Friday at 10 p.m. It said this was necessary “because of the persistence of extreme heat, high electricity use across its region and uncertainty in its wind forecast.”

SPP issues resource advisories when it expects extreme weather, significant outages, and/or wind- and load-forecast uncertainty in its service territory. They do not require public conservation.

July 12, 2022

MISO Defends 2030 Completion for DER Market Participation

MISO is insisting to FERC that it’s appropriate to take until 2030 before beginning the complicated task of opening its markets to distributed energy resource aggregators.

The grid operator filed a defense of its Order 2222 compliance plan with the commission last week, calling its proposed effective dates for registration (October 2029) and aggregations’ market participation (March 2030) “reasonable and appropriately tailored for the MISO region.” (See MISO Finalizes Plan for DER Market Participation in 2030.)

This comes after several members, state regulators and stakeholders said they were perplexed as to why MISO couldn’t accept DER aggregations after it replaces its market platform in 2024 or 2025. (See MISO Stakeholders Protest RTO’s Order 2222 Implementation Timeline.)

The RTO reminded FERC that its Order 2222 “recognized regional differences and directed each ISO/RTO to propose an implementation timeline that is reasonable for its respective markets” (ER22-1640).

Responding to the Organization of MISO States’ criticism that its plan is too drawn out, MISO said regulators can encourage participation in existing retail DER programs. The grid operator said retail regulatory authorities “have both the ability and authority to further develop and promote these programs” while MISO develops the systems and software necessary to implement Order 2222’s requirements.

MISO contended the “time between now and 2029 will be best used to work on other market and underlying system enhancements that it believes will make the full DER implementation process seamless and able to provide the most value.”

It also addressed arguments from clean energy and solar trade associations that the lengthy delivery time is tantamount to seeking a waiver of FERC compliance obligations. The RTO said that in addition to completing its market platform replacement, it needs another four years to overhaul its registration and enrollment system that is more than 10 years old. It also explained it must first introduce a multi-configuration resource participation model before it can tackle offers from DER aggregations.

MISO plans to use elements of its electric storage participation plan for DER aggregations. The aggregations must self-commit in the RTO’s markets based on their own forecasts and will be limited to a single pricing node.

July 12, 2022June 14, 2023

Stakeholders Question Feasibility, Costs of Con Ed OSW Substation

Stakeholders on Monday urged New York regulators to defer approval, outright reject or refer to NYISO’s public policy transmission planning process Consolidated Edison’s (NYSE:ED) proposal for a new substation in Brooklyn to integrate up to 6 GW of offshore wind energy (20-E-0197).

The utility would build the Brooklyn Clean Energy Hub on land it already owns adjacent to its Farragut Substation on the East River waterfront, a move it claims would save time and money, and also reduce interconnection costs compared to alternatives.

Stakeholders claimed that Con Ed’s proposal was long on optimism and short on details; complicated risk assessment for offshore wind developers preparing to respond to an imminent state solicitation; and should go through a competitive bidding process.

The Long Island Power Authority (LIPA) said that Con Ed’s April petition did not address the Public Service Commission’s January order that the utility provide specific information regarding why its existing substations cannot accommodate future offshore wind projects.

“The petition discussed and rejected a few alternative points of interconnection (Gowanus and Staten Island) but did not provide a comprehensive review of alternative points of interconnection (POIs) with associated cost estimates. Although the petition discussed the addition of a feeder and ring bus costs as being time- and cost-prohibitive elements associated with transmission interconnection at Gowanus, it provided few details associated with this analysis,” LIPA said.

In addition, NYISO’s Long Island OSW export public policy transmission need (PPTN) solicitation process is nearly complete and may result in a solution that itself creates interconnection headroom, thereby possibly reducing the need for the new hub. “The commission, therefore, should consider deferring its approval of costs of this magnitude until a PPTN proposal is selected,” LIPA said.

LS Power Grid and NextEra Energy Transmission New York reiterated calls for the PSC to refer Con Ed’s hub proposal to the NYISO planning process as a regional transmission project, calls that the commission rejected in its January order. (See NYPSC Mandates Meshed Offshore Tx Grids.)

While agreeing that the commission has significant authority over planning and siting, the NYISO competitive process nonetheless “is a powerful tool to achieve the goal of meeting [state] mandates at the least cost to ratepayers,” LS Power said.

The project as proposed by Con Ed is infeasible and presents significant challenges for OSW developers to permit and construct the necessary transmission lines, said NextEra.

“Con Edison assumes that OSW developers would utilize HVDC cables to reduce the number of cables required under the Verrazzano-Narrows Bridge and will site multiple converter stations near the water in New Jersey, Staten Island and/or Brooklyn. However, under Con Edison’s assumed scenario, the OSW developers would be required to install up to three HVAC cables from each converter station to connect to the hub project. Moreover, Con Edison assumes that the HVAC cables will connect to the hub project by water,” NextEra said.

To accommodate 6,000 MW of OSW generation, five HVDC and 15 HVAC cables will need to be installed in the Upper Bay; that many cables, as well as the requirement to site and install converter stations near the water as Con Ed has proposed, presents significant coordination, permitting and construction challenges, NextEra said.

“Independent developers should not be ignored in considering the Clean Energy Hub and its many surrounding implications,” said Anbaric Development Partners.

Inclusion of the Brooklyn Clean Energy Hub within Con Edison’s 345-kV system | Con Edison

Questioning the merits of interconnecting 4,500 to 6,000 MW of offshore wind “at essentially a single location,” New York City said that a climatic or other extreme event at that location could sever all of the offshore wind connections to the city, perhaps for an extended period of time.

As the state and city become more reliant on renewable resources and shut down its remaining fossil plants, a single interconnection location in Brooklyn for most offshore wind projects “could create unacceptable reliability and resilience risks,” the city said.

Con Ed also “creates a false sense of urgency” to support expedited approval of its petition, claiming the project is the only one that can be in service by 2027, LS Power said.

Even if the project could be completed by 2027, which is far from certain, there would not be anything to connect to it in that year. Rather, an OSW generator selected in the upcoming New York State Energy Research and Development Authority (NYSERDA) solicitation will most likely not be in service until after 2030, LS Power said.

The table lists NYISO published costs of interconnection for major generation facilities as compared to the Brooklyn Clean Energy Hub. | Con Edison

The New York Offshore Wind Alliance (NYOWA) said the commission should initiate a competitive procurement that examines the costs and benefits of a wider set of solutions, which should run in parallel with the third NYSERDA OREC solicitation, scheduled to be released imminently.

Developers preparing for the upcoming solicitation have been working to identify and de-risk interconnection options, and those efforts should not be overridden, NYOWA said.

Con Ed identified the site of the Hudson Avenue Units 3, 4 and 5 for the location of the project. LIPA said the company did not provide any comparative costs for using other in-city POI “that could be vacated by existing merchant steam plants at Astoria and Ravenswood, upon their future retirement. Consequently, the PSC’s decision would benefit from additional analysis as to whether alternative sites can be economically repurposed to interconnect offshore wind.”

LIPA also encouraged the commission to consider the risk of potential cost overruns, quoting Con Ed calling the new substation “a conceptual project that will require detailed engineering studies.” While the PSC requested an engineering cost estimate for the hub proposal, Con Ed provided no details about the studies behind or confidence level in the $1 billion cost estimate, LIPA said.