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November 13, 2024

FERC OKs MISO Outage Scheduling Rules, DR Testing

By Amanda Durish Cook

CARMEL, Ind. — FERC on Friday granted MISO permission to implement the remaining two proposals in its three-part short-term resource availability and need project.

Facing baseload generation retirements, more frequent emergencies and diminishing capacity margins, MISO had proposed stricter outage scheduling rules and annual real power testing for demand response. FERC said MISO could implement both provisions, though it wants the RTO’s Maintenance Margin tool chronicled in its Tariff.

In February, FERC approved a MISO proposal requiring owners of load-modifying resources to provide firmer and more clearly documented commitments regarding their availability. (See MISO LMR Capacity Rules Get FERC Approval.)

Taken together, the three filings are geared toward freeing up an additional 10 GW of supply as MISO navigates its spring maintenance outage season and the arrival of warm weather.

Stricter Outage Planning

MISO can now impose new generator accreditation penalties for planned outages taken during what it deems “low margin, high risk periods” (ER19-915). RTO staff have said the rules will incent the forward scheduling of planned generation outages.

FERC approved the proposal effective Monday and said it expected the rules will promote advanced scheduling, improve outage coordination and help MISO address its recent spate of shoulder period emergencies.

“MISO’s proposed Tariff revisions add specificity and incentives to the Tariff’s existing provisions governing the scheduling of generator planned outages,” FERC said.

MISO generation resources now must provide 120 days’ notice for planned outages. However, outages scheduled between 14 and 119 days in advance will be exempt from the RTO’s accreditation penalties, provided the outages are scheduled during predefined periods with adequate margins. Generator planned outages and derates scheduled fewer than 14 days in advance and occurring during a declared maximum generation emergency would be subject to accreditation penalties. The proposal also provides safe harbor provisions for resources that adjust a planned outage at MISO’s request.

The RTO also has instituted a transition period to the new set of outage rules. Outages scheduled prior to April 1 will not be subject to the accreditation penalty, while requests and revisions submitted April 1 and beyond for outages starting April 15 through July 29 would be exempt from the penalty if the request is submitted no later than 14 days in advance and MISO foresees “adequate projected margin at the time of the request.” The full set of outage requirements will go into effect for outages scheduled to start July 30 or later.

MISO said that although it has so far managed generation outages through voluntary rescheduling, “there has been a significant increase in the number of maximum generation emergencies that are at least in part driven by highly correlated generator planned outages.” The RTO said only 30% of planned outages are scheduled 120 days or more in advance, with most being scheduled just weeks in advance.

A group of state regulators and Prairie Power argued that MISO wasn’t providing enough detail into what load forecasts it uses in its Maintenance Margin tool, the nonpublic webpage the RTO maintains to help members schedule outages during adequate supply conditions.

The two also contended that MISO mischaracterized the accreditation penalty as an “incentive”; violated its stakeholder process by allowing just 11 days for stakeholders to review the final proposal; and that the proposal “ignores the real world of utility operations” in which previously unknown problems can be uncovered as equipment is disassembled. Indiana Municipal Power Agency and Southern Minnesota Municipal Power Agency also derided the 14-day deadline as “arbitrary.”

But FERC said the tiered approach “provides MISO with the forward transparency it seeks, reduces the risks associated with correlated [outages] and maintains sufficient flexibility for generator owners to schedule their [outages] without risk of an accreditation penalty.” FERC also pointed out that outages scheduled fewer than two weeks in advance aren’t automatically subject to an accreditation penalty unless the outage occurs during an emergency.

However, FERC agreed with WEC Utilities and American Municipal Power that MISO needs to define the Maintenance Margin in its Tariff. The tool “is the sole factor in determining whether there is an ‘adequate projected margin’ under the proposed Tariff revisions,” FERC said, and as such, should be recorded in the MISO Tariff.

“We find that the Maintenance Margin can have a significant impact on rates, terms and conditions of service,” the commission said, directing MISO to make a compliance filing by the end of April.

Real Power Testing for DR

FERC on Friday also approved MISO’s proposal to require annual actual power tests from its DR resources (ER19-651).

The RTO had asked for permission to conduct the tests to get more certainty about resources’ ability to perform when needed during tight operating conditions.

At MISO’s recent Board of Directors week in New Orleans, RTO executives said the move will put DR on a more level playing field with other resources, which are already beholden to the annual power tests.

DR resources that complete the annual testing will receive credit for one of the five deployments required of them in a planning year. MISO has said that resources that are deployed and follow all scheduling instructions in a planning year will not be subject to the testing in the following year.

MISO has also said it will waive the testing requirements for DR resources “that are subject to regulatory restrictions that preclude testing.” Additionally, a DR resource that simply wants to opt out of testing can do so, provided it agrees to pay MISO three times the cost of demand reduction for non- or underperformance.

Some MISO member companies protested the filing, arguing that the RTO failed to justify the need for annual testing; the testing would cause DR to exit the market; the proposed penalty cost was arbitrarily punitive; and an annual testing requirement would result in increased production costs and risk to equipment.

But FERC disagreed on all fronts.

“To the extent that MISO’s proposal increases costs on demand resource owners, they can reflect those costs in their submitted offers into the auction,” FERC said.

TSA Defends Pipeline Security Practices Before FERC

By Michael Brooks

WASHINGTON — Transportation Security Administration officials last week defended their efforts to protect the country’s natural gas pipelines, telling FERC they are adding more staff to the effort.

The importance of securing gas infrastructure was a recurring theme at a technical conference organized by FERC and the Department of Energy on security investments for energy infrastructure — an acknowledgement of the fuel’s growing importance to the country’s electric generation mix (AD19-12).

TSA — established under the newly created Department of Homeland Security after the Sept. 11, 2001, terrorist attacks — has come under increasing scrutiny in the last year over its role in securing pipelines.

Last June, the Houston Chronicle published an op-ed by FERC Chairman Neil Chatterjee and Commissioner Richard Glick that called on Congress to move responsibility for pipeline security from TSA to “an agency that fully comprehends the nation’s energy sector and has sufficient resources to address the growing cybersecurity threat to gas pipelines.”

Clockwise from foreground: TSA Administrator David Pekoske; FERC Commissioners Bernard McNamee, Cheryl LaFleur, Chair Neil Chatterjee and Richard Glick; and Bruce Walker, assistant secretary of DOE’s Office of Electricity. | © RTO Insider

The Government Accountability Office issued a critical report in December that noted TSA’s Pipeline Security Branch had only six full-time equivalent employees watching over more than 2.7 million miles of natural gas, oil and hazardous liquid pipelines.

In January, the U.S. Intelligence Community’s Worldwide Threat Assessment warned that Russia and China can launch cyberattacks that cause “localized, temporary disruptive effects on critical infrastructure,” such as pipelines. (See GAO Critical of TSA Pipeline Security Efforts.)

At a Senate Energy and Natural Resources Committee hearing on energy cybersecurity in February, some senators questioned whether Congress should give the pipeline job to a different, energy-focused agency. (See Senators Call for Urgency on Energy Cybersecurity.)

The GAO report suggested TSA’s pipeline role has been neglected by the agency in favor of airport security, a conclusion TSA Administrator David Pekoske did not dispute at Thursday’s hearing.

One of the criticisms of the GAO report was that “the agency has a detailed allocation plan for strategically aligning resources to screen passengers at TSA-regulated airports, but not for the entire agency.” Pekoske said that currently, all the agency’s inspectors, including those designated for surface transportation, are on the staffs of the 440 airports under TSA jurisdiction. “But we’re going to make a change to that,” he said.

Pipeline is one of the six modes of transportation under TSA’s jurisdiction, along with Aviation, Freight Rail, Highway & Motor Carrier, Postal & Shipping, and Mass Transit, according to the agency’s Cybersecurity Roadmap.

Pekoske also said he was consolidating the agency’s multiple “policy shops” into one. “I think there is a lot to be learned from security in other sectors that apply across the board, so all of our policy is going into one place.” He said he is also establishing regional offices co-located with the Federal Emergency Management Agency in New York City, Atlanta, Chicago, Dallas and Seattle.

“We already have a [regional presence] in place right now; it’s primarily purposed to support our aviation security mission,” he said. “I’m repurposing that … to advance the surface transportation security mission and also advance our contingency and planning response capability.”

David Pekoske | © RTO Insider

Another criticism of the GAO report was that TSA lacked a strategic workforce plan to identify the skills required of its employees, such as cybersecurity expertise. Pekoske said the agency was “working very hard on” investing in staff with cybersecurity expertise. It currently relies on DHS’ Cybersecurity and Infrastructure Security Agency, “but it’s my desire to have specific, industry-related cybersecurity expertise within TSA,” he said.

“We believe TSA has both the tools and the authority to address any threats within the pipeline industry,” said Sonya Proctor, the agency’s assistant administrator of surface operations. “As a result of the realignment of resources that the administrator has undertaken, we’re going to be able to increase the number of personnel focused on pipeline security, which means we will have a presence in the pipeline community on a very regular basis.”

Though TSA has the authority to issue mandatory standards, its voluntary Pipeline Security Guidelines “provide us the flexibility to address threats outside of the time-consuming regulatory process, which could conceivably take months or even years to go through,” Proctor said. She also noted that as administrator, Pekoske has the authority to issue mandatory directives to pipeline companies in the event of an emergency or serious threat.

Pekoske urged those listening to visit the agency’s website and view its 2018-2026 Strategy and Administrator’s Intent. Neither of these documents, however, specifically mentions pipelines.

Neither Pekoske nor Proctor mentioned current staffing levels, or how many people would be added.

Questions of Standards

TSA published the documents Pekoske mentioned shortly before the Chatterjee-Glick op-ed. Chatterjee has backed off somewhat on the recommendation that pipeline security be reassigned, telling senators and the National Association of Regulatory Utility Commissioners that he had been impressed by Pekoske’s and the industry’s efforts since the article’s publication.

“TSA and industry should have an opportunity to better address cybersecurity concerns on a voluntary basis before anyone imposes mandatory cybersecurity standards for gas pipelines,” he said Thursday.

Mark Gabriel, WAPA, speaks at FERC technical conference March 28 as (from left) William Evanina, National Counterintelligence and Security Center; Chuck Kosak, Department of Defense; Sonya Proctor, Transportation Security Administration; AEP CEO Nick Akins and NERC CEO James Robb listen. | © RTO Insider

Glick pressed Proctor about how the agency prioritizes its pipeline oversight. According to the GAO report, TSA takes the top 100 critical pipeline systems, ranked by the volume of fuel transported a year, and re-ranks them through a risk assessment that calculates threat, vulnerability and consequences to determine their priority in getting reviewed.

“Putting aside the 100, what do you do with regard to the rest of the pipeline system around the country, including the distribution pipelines?” Glick asked.

Proctor said that the agency isn’t limited to the top 100 when it conducts its reviews, “but clearly we’re looking at risk, and we’re looking at the resources we have to apply to that risk so that is where our focus is first.” She said the agency will have the capability to review more than the top 100 with Pekoske’s resource realignment.

The GAO report said that operators of at least 34 of the top 100 had identified no critical facilities, speculating that this was because TSA’s guidelines lack a clear definition of the criteria to determine facilities’ criticality. Glick asked Proctor if the agency only did reviews of pipelines that had identified critical facilities.

“That is the language in the Pipeline Security Guidelines, and that’s something we continue to discuss with the pipeline systems, so that’s an area we continue to work with,” Proctor responded.

Glick also asked Don Santa, CEO of the Interstate Natural Gas Association of America (INGAA), why the industry doesn’t support mandatory standards.

“INGAA thinks the current collaborative model with the Transportation Security Administration works well, and in fact it is improving,” Santa replied. “We think that, as Assistant Administrator Proctor described, it enables us to be more agile and reacting quickly to things than if we were in a mandatory situation. …

“Let’s focus on improving [TSA’s work], making it better [and] getting it to be what it can be, rather than on changing the model,” he concluded.

NERC CEO Jim Robb was noncommittal over whether there should be mandatory pipeline standards.

“The gas system and the electric system are so intertwined right now from a reliability perspective that the gas system has to have at least equivalent secure reliability to serve its needs as the electric system that’s built on top of it,” he said in response to a question from Glick. “So, whether it’s through a mandatory standards regime or some other regime than what TSA is doing today or just through the work that TSA is doing, I don’t really care so much about that. What I do care about is making sure that the gas is there when we need it.”

PJM Files Energy Price Formation Plan

By Christen Smith

PJM filed its energy price formation proposal with FERC on Friday, after a yearlong discussion with stakeholders produced no consensus.

The RTO said its plan — submitted unilaterally under Section 206 of the Federal Power Act — appropriately values energy reserves during times of stress. It said the proposal relies on concepts that have been used successfully by other RTOs to capture the real-time actions of grid operators, including a revised operating reserve demand curve (ORDC); improved utilization of existing capability for locational reserve needs; alignment of the day-ahead and real-time markets; and increased penalty factors (EL19-58).

“Proper price formation is critical to ensuring that prices reflect the value of the reserves required to operate the system. PJM’s proposal represents a major step forward in the design of the market,” said Stu Bresler, senior vice president of operations and markets, in a press release Friday. “These resources are not just critical to reliability today and in the future, they will provide the backup flexibility needed so that the grid is prepared for the continued integration of alternative sources of energy.”

PJM’s realignment of its reserve market under the proposal it filed with FERC | PJM

Bresler said renewable portfolio standards for D.C. and the RTO’s 13 states call for adding 25,000 MW of wind and 12,000 MW of solar by 2034, adding a level of complexity to reserves that existing rules don’t address. Ensuring reliability — and ultimately more competition and lower prices — depends on the reserve market reflecting the value of operator actions, Bresler said.

“There’s ample evidence that our reserve pricing needs to be reformed,” he told RTO Insider on Friday. In “41 out of the 48 hours of the polar vortex in January [2019], the price for synchronous reserve was at or near zero. To have the reserve price so close to zero, it doesn’t really make sense.”

Synchronized reserves are those able to provide power or remove demand within 10 minutes.

A Contentious Process

Despite meeting 23 times over 13 months beginning in January 2018, the Energy Price Formation Senior Task Force was unable to reach consensus. Tired of the stalemate, the PJM Board of Managers in December demanded staff move forward without member support if no consensus was reached by Jan. 31.

The Markets and Reliability Committee voted on five proposals in January, none of which cleared the two-thirds threshold required for a Section 205 filing under the FPA. Members protested the board’s deadline as “arbitrary,” but a last-ditch effort at compromise fell short on Feb. 6. (See Last Gasp Bid on Energy Price Formation Falls Short.)

The board agreed to submit staff’s proposal in mid-February. (See PJM Moves Forward with Own Energy Price Formation Plan.)

Staff, however, did grant the unusual step of seeking feedback from stakeholders on the filing before submitting it to FERC. The March 14 meeting produced “helpful” input, said Bresler, who noted that staff asked the commission for an extended 45-day comment period to give members ample time to weigh in.

“Frankly, I hope we never have to use this [Section 206] process again,” he said. “But we do think that it is beneficial to get stakeholder feedback, because they usually do point out things that are a benefit to clarify in the language.”

American Municipal Power CEO Marc Gerken said on Wednesday he believed the board’s deadline pressured staff into filing prematurely, leaving the door open for market flaws. (See related story, Rushing Price Formation Filing Unwise, AMP Tells PJM.)

He also criticized the RTO for tweaking the language in its proposal after the Jan. 24 MRC meeting. PJM posted slides detailing these revisions just 24 hours before the March 14 meeting, he said, which wasn’t enough time to review and respond to such “significant” alterations.

Bresler disagreed with Gerken’s characterizations of the process. “I think it’s reasonable to expect that with a proposal like this there are many details that fall under the major components, if you will, that are in constant flux. You saw that with the voting process during stakeholder meetings,” he said. “It’s reasonable to expect that that’s going to be the case. I think we were getting down to a level of detail that we needed to ensure that we had a complete proposal.”

Section 206 filings come with no statutory deadlines, though PJM requested the commission rule by Dec. 15 in order for the RTO to implement changes by June 1, 2020.

Ex-Fire Chief Shares 9/11 Lessons at NERC Conference

By Rich Heidorn Jr.

ATLANTA — The ballroom at NERC’s Human Performance Conference was pin-drop quiet Wednesday as Joseph W. Pfeifer, former chief of counterterrorism and emergency preparedness for the New York City Fire Department, gave an hourlong speech recounting his experience leading firefighters into the World Trade Center on Sept. 11, 2001.

Joseph W. Pfeifer, former chief of counterterrorism and emergency preparedness for the New York Fire Department | © RTO Insider

Pfeifer’s experience was captured in brothers Gédéon and Jules Naudet’s documentary, “9/11.”

One of the filmmakers accompanied Pfeifer, then a battalion chief, as he and his men rushed to the World Trade Center after the North Tower was hit by the first highjacked airliner at 8:46 a.m. The film captured the chaos and confusion when the second plane hit the South Tower at 9:03 a.m., then the collapse of the South Tower at 9:59 a.m., which left the glass-walled lobby of the North Tower pitch black.

It was then that Pfeifer ordered his firefighters to abandon rescue efforts and evacuate the North Tower, he told the conference, which was co-hosted by the Department of Energy and the North American Transmission Forum.

“That sounds like a simple order when you look back in hindsight. I had no idea that the whole [South Tower] had collapsed. I thought the only people in trouble were us. But giving an order where you are pulling the rescuers out and leaving a thousand people behind is not an easy order at all. But it’s using that two parts of the brain — the intuitive part and the analytical part.”

Pfeifer was back out on the street when the second tower collapsed at 10:28 a.m., sending him and others running away.

Pfeifer said the event illustrated “organizational bias” — how firefighters, EMTs and police tend to stay in their own groups even when working together.

Battalion Chief Joseph W. Pfeifer at the World Trade Center on 9/11 before the collapse of the South Tower | Jules and Gédéon Naudet

After the first tower collapsed, police in a helicopter circling the North Tower reported that the building’s top 15 floors were “turning red” and the corner of the building was starting to buckle. “‘Pull everybody back three blocks,’” Pfeifer said the copter warned, fearing the second building’s collapse.

“That message never got through to the fire department, and the fire department never asked,” Pfeifer said. “Here you have two great organizations — NYPD and FDNY — and they didn’t talk to each other at the most critical time.”

Some 71 law enforcement officers and 343 firefighters — including Pfeifer’s brother — died that day, along with almost 3,000 civilians. Among those killed were the top-ranking firefighter on the scene and other command chiefs.

“We had no command staff. They were all gone. So how do you re-establish command?” Pfeifer asked.

Battalion Chief Joseph W. Pfeifer (right) and other commanders at the World Trade Center command post on 9/11 | Jules and Gédéon Naudet

After the second building toppled, Pfeifer recalled, his immediate boss, Deputy Assistant Chief Peter Hayden, got on top of a burned-out fire truck and gathered the surviving firefighters and reinforcements together.

“The chief said, ‘I want you to take off your helmets, and we’re going to have a moment of silence, because we lost a lot of people today,’” Pfeifer recalled. “And we took off our helmets.

“And then he asked us to put back on our helmets. And in the moment of putting back on the helmets, he re-established command, because there was a lot of stuff to do. There were rescues to be made, and fires to be put out. But what he did, he used what I’m calling now ‘crisis empathy.’ … He listened to what we were feeling.

“We knew it was bad, and we knew we lost a lot of people, but by him being able to recognize that and then articulate it, [it] made all the difference in the world and it re-established command. So, sometimes those small gestures mean a lot more than it sounds.”

PNM’s Bid to Join Western EIM Gets Approved in Part

By Hudson Sangree

In a case that’s grown increasingly convoluted, state regulators last week granted two of the approvals Public Service Company of New Mexico (PNM) had requested to join CAISO’s Western Energy Imbalance Market, but they denied one concession the utility deemed key (18-00261-UT).

The New Mexico Public Regulation Commission found that PNM had complied with state filing requirements and authorized the utility to create a regulatory asset that would allow it to seek cost recovery in a future rate case.

The commission had approved the same two requests for joining the EIM in December, but it vacated the order in February and reconsidered the matter, to the surprise of PNM and environmental groups that supported the move.

Public Service Company of New Mexico has sought to join the Western EIM partly because it facilitates trade in renewable power across the West. | PNM

In its latest order, issued Wednesday, the PRC balked at a third request by New Mexico’s largest utility to “find that it is reasonable to join the EIM and expend necessary funds to do so.” The commission decided PNM was asking it to approve the costs to join the market in advance, without proof of a net public benefit.

PNM estimated it would incur about $29 million in capital costs and expenses, including for 19 new staff positions and computer systems.

“No party objects to the most obvious interpretation [of the reasonableness request], i.e. that PNM seeks approval to join the EIM. But PNM states that it is not seeking commission approval to join the EIM,” Hearing Examiner Ashley Schannauer wrote in her recommended decision, which the PRC’s five commissioners unanimously adopted.

PNM contended it didn’t need the PRC’s approval to join the EIM because it wasn’t necessary for the provision of adequate service, nor was it required by any commission rule or regulatory mandate.

What the utility wanted, Schannauer wrote, amounted to a guarantee that it would get reimbursement of its expenses plus a return on its investment in the form of profits. The hearing examiner concluded PNM was trying to shift the financial risk of joining the EIM from its shareholders to ratepayers.

“PNM asks that it be allowed to recover its costs as long as they are consistent with the estimates provided in this case and as long as the specific costs it incurs are reasonable,” Schannauer wrote. “Ratepayers would be required to pay all of those costs whether the EIM actually produces savings or not.”

The commission agreed with Schannauer that it lacked legal authority to approve “ratemaking treatment in advance of a rate case.” Regulators in other states hadn’t granted their utilities such preferential treatment for joining the EIM, the PRC noted. In a 2014 filing with Oregon regulators, PacifiCorp, the EIM’s first member, asked to defer until a future general rate case the recovery of $20 million in start-up costs required to bring its six-state system into the market.

PNM issued a statement saying it was “profoundly disappointed” that the PRC hadn’t clearly acknowledged the prudency of joining the EIM.

“Membership in the EIM has resulted in cost savings exceeding a half billion dollars for utility companies’ customers since 2014,” PNM said. “In New Mexico, that would produce savings conservatively projected at $10 million annually for PNM customers, increasing to over $20 million annually in the next decade.”

Convoluted Case

The case has taken a series of unexpected turns since PNM declared its intent to join the EIM last August. (See PNM Seeks to Join Energy Imbalance Market.) Initially it seemed as if the utility were merely looking for a nod of approval from regulators, along with a mechanism for eventually recovering its upfront costs.

PNM serves more than 500,000 customers across New Mexico. | PNM

The EIM is entirely voluntary and largely noncontroversial. Proponents have credited the intra-hour, interstate market with increasing the exchange of electricity among Western states, especially power generated from wind and solar resources, and with saving its participants nearly $565 million in the past five years.

On Dec. 19, the commission approved PNM’s application to join the EIM and said the utility’s next general rate case would bear the burden of showing its costs were reasonable and consistent with the estimates presented to the PRC. (See New Mexico Regulators Say PNM Can Join EIM.)

In that decision, the PRC acknowledged staff’s recommendation “that the commission make clear that approval to create the regulatory asset is not a guarantee that the actual costs will be found to be reasonable or prudent. Staff notes that PNM will have the opportunity to support the reasonableness of those costs during its next general rate case and further notes that PNM has acknowledged that the commission will retain final ratemaking review and authority over costs in PNM’s next rate case.”

Then, in mid-January, the Albuquerque Bernalillo County Water Utility Authority, which had opposed the creation of a regulatory asset all along, asked the PRC to reconsider its December order. The commission granted that request Feb. 6 after two new commissioners were sworn in. The news had worried EIM backers that it could delay PNM’s membership in the market for another year and cost ratepayers $10 million in projected annual benefits. (See State Regulators to Re-examine PNM’s EIM Membership.)

Latest Order

The PRC dealt with the matter on an expedited schedule to meet the April 1 deadline.

In its Wednesday order, the PRC said it “does not oppose” PNM joining the EIM, and it gave PNM authority, in the form of an accounting order, to create a regulatory asset to record its expenses and to seek compensation.

However, the commission said the utility’s EIM-related costs and the reasonableness of its expenditures should be decided in the future rate case.

“Preapproval of reasonableness at this juncture in the case would be premature, given that a future determination ultimately must be made that such costs are proven to be reasonable or unreasonable,” the commission said.

It ordered PNM to file annual reports of its EIM costs and savings and CAISO’s quarterly reports on EIM benefits.

PNM did not say if still intended to move forward with joining the EIM in 2021. (See New Mexico Moves Toward Clean Energy, EIM Participation.) “We will not have any further comment until we have time to fully review and evaluate the final order,” the utility said in an email.

NERC Conference Ponders the Human Element to Reliability

By Rich Heidorn Jr.

James Merlo | © RTO Insider

ATLANTA — When NERC considers a new reliability standard, it convenes drafting teams heavy on engineering expertise and system operations. But for its eighth annual Human Performance Conference last week, NERC brought in firefighters, psychologists and speakers from the airline industry to provide lessons.

“We find that all industries have people, people who actually operate the same way, whether they’re moving electrons or moving aircraft,” explained NERC Vice President and Director of Reliability Risk Management James Merlo, who served as master of ceremonies for the three-day event, co-hosted by the Department of Energy and the North American Transmission Forum (NATF).

The conference attracted more than 400 attendees from 180 organizations, including linemen, control room operators — and at least one utility billing analyst, who said he attended because his company uses root-cause analysis on billing errors.

More than 400 attendees from 180 organizations attended the eighth annual Human Performance Conference. | © RTO Insider

NATF HP Assistance Visits

At the beginning of the conference, NERC CEO Jim Robb signed a new memorandum of understanding with NATF, whose 7,400 subject matter experts conduct peer reviews to promote “excellence and continual improvement.”

Tom Galloway | © RTO Insider

The nearly 90 companies in NATF operate 80% of transmission of 200-kV and higher. “It’s an impactful set of members,” NATF CEO Tom Galloway said. “If we get the forum oriented on a topic, we can typically move the ball forward pretty well.”

Representatives of MISO, Arizona Public Service and Tri-State Generation and Transmission Association shared their experiences with inviting NATF to visit.

MISO’s John Rymer, who formerly worked in transmission substation operations for Duke Energy, said he asked NATF to help transfer human performance (HP) tools from the field to the RTO’s control room. “These assistance visits really help you pinpoint where you need to concentrate your efforts,” he said.

John Rymer | © RTO Insider

Rymer said he is looking for “low-hanging fruit” in spreading the HP message in real-time and control-room operations first. “You can move that upstream or downstream in our organization, because engineering, IT, all these groups, can utilize the same tools,” he said.

Sage Williams, manager of Tri-State’s Eastern maintenance region, agreed. “HP can affect not just field guys. It’s your entire organization: engineering, system operations,” he said.

Sharing Mistakes, Using Technology

Digger derricks — utility trucks with augers for digging holes for poles and boom-mounted hydraulic lifts for working on wires — played supporting roles in stories by several speakers who shared mistakes they made as linemen.

Sage Williams | © RTO Insider

In a talk titled, “How strong character improves safety and reliability,” former lineman Jeff White, now an HP consultant with Applied Learning Science, recounted how his truck flipped on its side when soft ground gave way underneath its outriggers while he was installing a pole on a new golf course.

After the crew used a second truck to get the first one back on its tires and wiped off the mud, the lead lineman told White and the other crew members not to report the incident. “‘This was a nonevent. What you just witnessed, erase from your memory.’”

White initially agreed, but after a sleepless night, he told his foreman of the incident the next day, fearful that the truck might have sustained unseen damage that could result in an injury to another worker.

A conference attendee tries 3DInternet’s virtual reality demonstration. | © RTO Insider

“What if the bolts on that turntable — half of them are broken and we can’t see them? What if there’s factures in that steel that we can’t see? I need to speak up,” White said.

Jeff White | © RTO Insider

In another presentation, MidAmerican Energy displayed 3D recreations of field accidents, crafted by 3DInternet.

Mike Buntz, a MidAmerican line crew foreman, narrated an animation of a near tragedy that occurred while replacing a rotten utility pole. The truck became fully energized when its boom contacted an overhead wire, setting the grass around it on fire. Luckily, no one was injured.

“It wasn’t one of my prouder moments,” Buntz said. “But I agreed [to participate in the animation] hoping that I could help somebody down the road.”

“One of the things that we learned about using these 3D animations is it helps us to have a better appreciation of what actions made sense at the time … what happened and why,” said Sam Reno, MidAmerican’s performance improvement program manager. MidAmerican also is using GoPro cameras mounted on hardhats to produce training videos.

Peter Jackson | © RTO Insider

Peter Jackson, an HP coordinator for Georgia Power, said utilities often have “brittle systems” that assume 100% error-free performance.

Mike Buntz | © RTO Insider

He demonstrated a pilot program using visualization technology that turns an iPad into a situational awareness tool that shows real-time data on substation equipment’s health and other metrics.

Jackson said the tools can help utilities deal with the loss of experience as more of their aging workforce retires.

“We think that this really helps our guys build a deeper knowledge of the tasks and how to do it right,” he said. “We also think there’s an application potential for everything from troubleshooting to [simulations of] high-risk tasks.”

MidAmerican Energy is using 3D animations to share lessons from accidents. | © RTO Insider

Answers from the Field

Michelle Miller and former colleague Monika Bay recounted their efforts to improve worker safety at Baltimore Gas and Electric after the electrocution of a worker at a substation.

“You can have the best intervention design in the world, but if you cannot convey it in a way that connects with the head and the heart of these front-line empl

Michelle Miller (background) and Monika Bay | © RTO Insider

oyees you will not be successful,” said Bay, who left BGE a year ago to start her own company, Safety & Operational Risk Solutions.

Bay said sustaining improvement “is by far the hardest part. This is really about line leaders keeping the language alive — keeping these concepts alive in their own workgroups.”

After her and Miller’s work, workers in the field started bringing risks to them, Bay said.

One such issue: the potentially fatal consequences of confusing a black, yellow-striped electric line with a nearly identical black, yellow-striped, three-quarters-inch, high-pressure, plastic gas pipe.

Following a BGE project to improve worker safety, the utility’s field workers informed their managers of dangers from the company’s nearly identical gas (right) and electric lines. | © RTO Insider

At BGE, gas lines are supposed to be buried 2 feet below ground, with electrical lines a foot below them. In practice, however, the lines can get transposed, meaning a worker expecting to cut a gas line could end up getting electrocuted by cutting the electric cable. The only apparent difference between the two: The gas pipe has four stripes; the electric cable only three.

“It’s 2 o’clock in the morning, I’m a gas mechanic, I’m 2 feet down in the hole, it’s raining and muddy, and I’m going to tell the difference?” Bay said.

“It wasn’t just this: We had 16 pairs of assets where the gas and electric looked very similar.”

Although BGE had changed to all yellow gas service pipe about 1998, the risk of confusion remained with older pipe. In response, Bay said, BGE formed a joint team of field workers, engineers and training personnel to address the risk through enhanced training, instrumentation and work practices.

“System design often puts risk into the hands of the employees,” she said. “Sometimes we don’t know some of the risk that front-line guys are dealing with because they’re just dealing with it.”

Lessons from the Airlines

Christian Vehrs of Delta Air Lines used an example of how a fuel heater valve was confused with a nearly identical engine anti-icing valve because of time pressures, insufficient paperwork, unfamiliarity with the task, and confirmation bias.

Christian Vehrs | © RTO Insider

David Marx of Outcome Engenuity used dice to illustrate resilient systems. The more dice you roll, he said, the more redundancy — like setting multiple alarm clocks to prevent oversleeping.

The redundancy provided by multiple “dice” is essential in aeronautics, he said, because while Federal Aviation Administration rules require a 1 in 1 billion chance of failure, “nobody can design a part that will never fail.”

Marx used the experience of pilot Chesley “Sully” Sullenberger, who famously landed his Airbus A320 on the Hudson River when his engines failed after striking a flock of Canada geese shortly after takeoff from LaGuardia Airport in 2009.

Airline engines are expected to fail only once in every 50,000 hours. Because planes must have two engines, the chances of both failing simultaneously should be 50,0002, or 1 in 2.5 billion, Marx noted.

In Sullenberger’s case, however, LaGuardia was near a landfill that attracted birds, meaning the dice were “stuck together,” Marx said. (Airport officials increased their bird-killing programs after the incident.)

David Marx | © RTO Insider

In another example, Marx cited a woman who died in 2017 after mistakenly being given a paralytic, vecuronium, instead of the mild sedative midazolam — marketed under the brand name Versed — that had been prescribed for her during a PET scan.

Hospital procedures set four “dice,” starting with an automated dispensary stocked with the drugs. A nurse mistakenly chose the wrong drug when the autocomplete function gave her options after typing the letters “V-E.”

The nurse then failed to check the drug at the dispensary or later when she delivered it to the patient. Finally, the fourth die was the nurse’s failure to remain with the patient to monitor her reaction to the drug.

“What should have been four dice became one,” he said — the active failure of choosing the wrong drug compounded by the nurse’s failure to perform the other three safeguards. The nurse is now facing reckless homicide charges.

Marx said the incident illustrated why many of us ignore speed-limit signs but slow down when we see a police car.

“We are not inherently rule followers; we are hazard and threat avoiders,” he said. “The police officer represents consequence. The sign just represents the rule.”

Lessons from the Football Field

Dave Sowers of Knowledge Vine used a video of the play known as the “Prayer at Jordan-Hare” — Auburn University quarterback Nick Marshall’s unlikely 2013 game-winning touchdown pass over the University of Georgia — in a discussion on the role of luck.

Dave Sowers | © RTO Insider

It was 4th and 18 with 36 seconds left in the fourth quarter. Auburn Head Coach Gus Malzahn called for a pass to get the first down, which would have put the team into field goal range. And the intended receiver was wide open as a second receiver went deep, drawing triple coverage. Marshall unwisely threw the ball to the deeper receiver, but two of the Georgia defenders collided, one tipping the ball into the hands of the receiver, who ran into the end zone untouched.

Marshall was lucky in that instance, but his gunslinger judgment ultimately proved his undoing, as too many of his passes ended up intercepted. “That’s why he’s not playing on Sundays” in the NFL, Sowers said. Instead, he plays for the Canadian Football League’s Saskatchewan Roughriders.

HP in the Control Room

Mohammed Alfayyoumi recounted the changes he made since becoming director of Dominion Energy’s transmission system operations center.

He spread out the workload by scheduling switching orders throughout the week rather than having them all on Mondays. He doubled the operations staff to four per shift after benchmarking Dominion’s staffing against similar-sized utilities.

Mohammad Alfayyoumi | © RTO Insider

He also increased simulator training, began near-miss reporting and training in root-cause analysis, and eliminated work that didn’t add value by automating 6,000 phone calls per week.

Operator hiring was improved by adding testing and screening, including more complex behavioral interviews.

“We invest a lot in steel and copper but not a lot in humans,” Alfayyoumi said. “Operator selection is vital to human performance, because you cannot fix poor selection. If you hire the wrong operator, there’s nothing you can do to make him better,” he said.

Adaptive vs. Procedural Systems

Consultant Jake Mazulewicz made the case for “adaptive” over “procedural” systems, recounting a conversation with an employee for an unnamed company who complained it had become excessively dependent on procedures.

“He said when an incident happens, even something small — someone cuts themselves with a knife, no stitches, very small stuff — everybody hears about it. And within two or three weeks you can bet your next paycheck that [the] safety and training [department] is going to say … ‘Here’s a new and updated procedure to make sure that never happens again.’

Jake Mazulewicz | © RTO Insider

“Nobody even bothers reading the new procedures … because it doesn’t matter, because it’s going to change,” Mazulewicz continued.

Under system-based thinking, he said, “when you see an error … you don’t think who’s wrong, you think that’s a signal that my … system could use some improvement. … Almost every incident we’re talking about is triggered by human error, but it’s caused by a whole lot of other things: latent organizational weaknesses, previous decisions, things like that.

“How do you minimize errors in a system-based thinking? You improve your system. … You make it hard for people to do the wrong thing, and you make it easy for people to do the right thing.”

Expanded MRO Winds down SPP RE Transition Period

By Amanda Durish Cook

ST. PAUL, Minn. — The Midwest Reliability Organization is winding down transition activities after a year of expansion that doubled its territory and regulatory responsibility.

The organization’s Board of Directors voted unanimously Thursday to approve the dissolution of a special oversight committee on the transition of former SPP Regional Entity members to MRO.

MRO board members in round table format | © RTO Insider

Board Chair Silvia Parada Mitchell opened the meeting with an analogy related to weather in Minnesota’s Twin Cities, which were experiencing the first warm days of spring. The board last met during the snowiest February on record for St. Paul, when 9 inches of fresh snow prevented some board members from appearing in person. She likened the weather change to MRO’s recent transformation.

“For us in 2019, that’s what we’re seeing in MRO. We are thriving with the opportunities of last year, and we will continue to thrive,” Parada Mitchell said. “I think this is a great beginning.”

Silvia Parada Mitchell | © RTO Insider

Parada Mitchell pointed to the “expanded and more diverse board,” which now consists of 23 members after MRO leadership added both independent and regional stakeholders to represent newly joining entities.

Board members at the Thursday meeting were arranged in a new roundtable seating format to make it “more inclusive,” Parada Mitchell said.

MRO’s annual report noted the expansion “essentially doubled MRO’s regional footprint and regulatory responsibilities.” The merger “necessitated numerous governance and policy changes” and “provided us the opportunity to rethink MRO’s structure,” Parada Mitchell said.

SPP dissolved its regional entity in late August after citing a mismatch its footprint and that of the RE. MRO took most of its members, with SERC Reliability signing on the remainder. (See SPP Closes Book on Regional Entity.) The move provided MRO with about 100 SPP registered entities and territory in Kansas and Oklahoma, along with parts of Missouri, Arkansas, Louisiana, Texas and New Mexico.

MRO began 2018 with 102 registered entities performing 326 reliability functions and closed the year with 194 registered entities performing 556 reliability functions.

MRO President and CEO Sara Patrick said the organization is currently sharing its lessons learned and transition advice as SERC prepares to absorb the dissolving Florida Reliability Coordinating Council in early summer.

Sara Patrick | © RTO Insider

“We’ve been working with SERC to share our experiences,” Patrick said.

MRO in 2018 managed two separate budgets: its usual, preapproved annual budget, and about $2.1 million in transition-related costs, which will be covered by a transfer of assessments from SPP RE. To handle the transition, MRO hired 12 additional staff members and remodeled its St. Paul offices. MRO originally budgeted $1.5 million for the transition.

The merger had impacts on MRO’s 2018 financial performance and revenues. Last year, the organization recorded $15.6 million in operating revenue and $13.5 million in operating expenses, with about $2.7 million in operating income. Baker Tilly partner Nicki Donlon, who completed a February financial audit of 2018 expenses, called the performance a “healthy balance sheet.” Expenses were in excess of MRO’s original $11.7 million budget for 2018. Taken together, the two budgets exceeded the organization’s FERC-approved budget by about 9%.

The organization also recorded about $9 million in assets and $3.7 million in liabilities. By contrast, it had $6 million in assets and roughly $3.5 million in liabilities in 2017, with $10.7 million in operating revenue and $10.8 million in operating expenses, resulting in a small loss in operating income.

MRO said this year it will focus on integrating even more new registered entities. The organization has forecasted spending about $16 million during the year.

Ron Gunderson, chair of the organization’s Reliability Advisory Council, said his group this year will also focus on “near misses” in addition to the usual focus on outright reliability violations. He said the group is interested in events that almost — but not quite — rise to reliability issues.

MRO General Counsel Miggie Cramblit said the organization will also work in 2019 to make introductions to state regulators to increase awareness of its reliability role.

“There’s some confusion that we are MISO instead of MRO,” Cramblit said.

Staff also said they’re considering hosting future workshops and conferences in more southern locations in order to accommodate new members.

MISO Contemplates DER Effect, Possible Rules

By Amanda Durish Cook

CARMEL, Ind. — MISO may have to contend with security concerns, communication constraints and even the eventual phaseout of the vertically integrated utility model as it strives to manage a grid with growing amounts of distributed energy resources.

Those possible scenarios were laid out March 26 at the latest in a series of educational workshops hosted by the RTO and the Organization of MISO States. The events are a precursor to MISO bringing discussion of DER market rules to its stakeholder process.

The first workshop on DERs in late January was cut short by a dangerous cold snap that knocked out power to MISO’s Carmel headquarters. (See Cold Snap Halts DER Talk as MISO Calls Max Gen Event.) The RTO has planned two additional workshops more technical in nature for April 9-10 and April 17-18.

Solar panels in Indianapolis | © RTO Insider

Located far from the coasts, the Midwest and South are typically slow to take up new energy trends. MISO has a relatively low level of DERs on its system, with a 2018 OMS survey finding about 2.6 GW (compared with about 6 GW in the geographically smaller CAISO footprint). But Bob Shively, president of training firm Enerdynamics, said MISO’s volume is “significant” and predicted that DER will grow — albeit lopsidedly — based on state politics and regulation.

MISO DER Program Manager Kristin Swenson said it’s appropriate for discussions to happen now, even if adoption is currently relatively low.

“The rate of change seems very slow until it happens all at once. … Political, regulatory changes happen quickly, and it takes a long time to prepare,” Swenson said. “Now is the time to be looking at what’s going to be five years, 10 years away.”

Shively said DERs are fast becoming economic: “There’s this distinct possibility that DER penetration is happening very quickly out there, and it will have impacts on the bulk electric system.”

T&D Communication

Shively said MISO and its members must now figure out how to improve communication at the transmission and distribution interface to increase visibility and determine what wholesale market changes are needed to include aggregated DER.

“There’s going to be a coordination and discussion that never took place in the past,” Shively said, adding that metering DERs will one day become a “necessity.” He said the distribution grid will likely become a data monitor and automated system in addition to a power delivery system. Distribution operators may soon be scheduling generation, Shively said, or form distribution-level system operators to optimize the use of DERs. He also said MISO may need to devise a special interconnection agreement for DER aggregations.

“This is not going to happen overnight, but there are some models being talked about out there,” Shively told stakeholders.

Currently, MISO has neither visibility nor situational awareness about the location or output of DERs in its footprint, and management thinks it possible that FERC will issue rules on the treatment of DERs this year. The grid operator also predicts that DERs will require “new gird management protocols” as the transmission grid, distribution grid and end users begin flowing energy between one another, deviating from the traditional pattern of one-way flows.

But Shively said changes to incorporate DERs must be made thoughtfully, with special attention on system frequency, voltage and resource adequacy.

“When we’re planning the system, the No. 1 thing is we don’t want to break the system,” he said. “So if we’re bringing DERs on … we want to make sure that we’re not doing things to damage our equipment.”

He said to maintain frequency, utilities can control generation and might someday control even load courtesy of smart devices.

Shively also pointed out that there’s no dollar value placed on reactive power to control voltage and no incentive to provide it. “Unless you want to be a good corporate citizen,” he chuckled. He added that voltage instability will likely be localized and managed on the distribution circuit and said frequency issues are the bigger threat to the grid.

‘Points of Entry’

Stakeholders pointed out that DERs open the question of what generation falls under NERC Critical Infrastructure Protection standards. Shively said DERs open new “points of entry” to the grid. He said it’s possible that hackers could access controllable home systems.

But he also pointed out benefits, saying DERs could potentially provide black start services to restore the grid from blackout.

Stakeholders asked about the difference between a DER and a more energy efficient refrigerator, when both serve to reduce load.

“It starts to get really fuzzy: What is a DER and what isn’t a DER. … So the answer is, it’s a fuzzy line, not a fine line,” Shively said. “Is a Nest thermostat that changes your temperature a DER, or is it just customer behavior?”

Shively said MISO will have to keep in mind that its DER supply mix will directly result from state processes, but it’s up to the RTO to plan the system and model load. That will prove difficult for grid operators that lack visibility of DER behavior, he said. Shively said MISO should also consider that line maintenance can take multiple DERs out of service.

Minnesota Public Utilities Commission staff member Hwikwon Ham recommended MISO differentiate its future operational concerns from its planning reserve concerns regarding DER integration. The RTO has said it may have to rethink its planning reserve margin as resource availability shifts. (See MISO, Stakeholders Debate Merits of Seasonal Auction.)

Others’ Load

WPPI Energy economist Valy Goepfrich observed that the MISO system only seems to encounter complexities when a DER owner goes from serving its own load to serving others. She asked if MISO might only have to make changes when groups of DERs enter the wholesale market en masse.

But Shively said even when customers choose to serve their own load with DERs, load modeling becomes a problem. He said under that scenario, data exchanges will still be needed between distribution and transmission.

“I think you’re right; it’s probably a spectrum” of grid preparation based on DER use, Shively said.

Shively also said that once new guidelines for visibility and control are in place, MISO members can’t assume that existing communications systems will be adequate. He pointed to rural areas that lack high-speed internet.

But he said the DER discussion is reminiscent of the fears he heard when utility-scale wind and solar were being integrated into the system. However, he allowed that the question of generation on the distribution level muddies the regulatory waters.

Vertical Integration

Stakeholders asked how increasing use of DERs would interact with the largely vertically integrated utility model in the MISO footprint.

Shively paused. “That’s a great question.” But, after a beat, he said, “I think that there’s going to be more pressure for customers to have retail choice. … I would contend you can go down the road for a while without retail choice, but the more you crack open the door…”

He trailed off, later adding that companies like Google and Amazon might lead the way on pushing for supplier choice.

At the end of day, Shively said, the difficulties of absorbing DERs into the market should prove worth the effort.

“We can come up with lots of problems with implementing DERs, but we also have to remember there’s a lot of potential,” he said. “I think, long-term, DERs can provide low-cost reliable service to customers. That’s the goal of what all this should be.”

Analysis Group Presents NYISO Carbon Pricing Study Plan

By Michael Kuser

RENSSELAER, N.Y. — Stakeholders expressed some skepticism last week as the Analysis Group revealed the outline of a new study underway to provide insights into pricing carbon in NYISO’s markets.

The ISO surprised stakeholders in February when it announced it had commissioned Analysis Group to supplement the Brattle Group’s foundational study in order to finalize a pricing scheme. (See NYISO Commissions New Social Cost of Carbon Study.)

Susan Tierney, a senior adviser with Analysis Group, allayed their concerns with poise and humor as she told the Installed Capacity/Market Issues Working Group on Thursday that she and colleague Paul Hibbard “had some ideas for additional things that we didn’t think were captured in the Brattle report, starting with macroeconomic or co-benefits, known as extra-market activities,” and second, discussing “some reasonable but less conservative assumptions.”

The firm plans to present preliminary findings and discuss with stakeholders the study approaches by the end of the month, present initial analysis results in mid-May, and prepare a white paper and companion technical report by the end of May, Tierney said.

A task force created in October 2017 by NYISO and the New York Public Service Commission worked for more than a year developing a carbon pricing proposal. In December it turned the proposal and final details over to the ISO’s stakeholder process. (See IPPTF Hands off Carbon Pricing Proposal to NYISO.)

Stakeholders Question

Stakeholders were quick to tell Tierney that it’s not easy to put together a carbon pricing report in a couple months and contribute to a policymaking process that’s been going on for nearly two years.

“Is this going to be something unbiased that looks at both sides of the issue, or just looks for benefits that Brattle might have missed?” said Couch White attorney Michael Mager, who represents Multiple Intervenors, a coalition of large industrial, commercial and institutional energy customers. “Will you not look for costs and co-damages; effects on jobs; manufacturing; emissions in other states?”

“We want to do credible analysis, so of course we look at pluses and minuses, positive and negative impacts,” Tierney said.

Couch White attorney Kevin Lang, representing New York City, reacted to a presentation slide with a photo of the city skyline in haze, and captions that said most emissions reductions will be “downstate” and that the greater metropolitan area has the 10th worst ozone air quality in the U.S.

“Your assumption that New York City will benefit from improvements in air quality is flawed, as Brattle acknowledged that carbon pricing would not reduce fossil fuel-based generation in the city, and that what Brattle termed ‘downstate’ included Zone F [the capital region and upper Hudson River Valley],” Lang said.

Tierney said she probably conflated the terms, but she insisted that they were not redoing or critiquing the Brattle report, and that they would indeed be looking at statewide co-benefits — and negative impacts.

“Co-benefits is a term used in Washington for things that are not the intended effects of a policy,” Tierney said. “When looking at employment impacts, for example, we know we can’t just count up the new jobs without considering the jobs that might be lost.”

NYISO
Brattle found that a carbon charge would induce steam unit repowering downstate, which could benefit public health by improving the air quality in New York City. | NYC Department of Environmental Protection

Erin Hogan, representing the New York Department of State’s Utility Intervention Unit, said the study should allow stakeholders to understand the net employment impacts, not gross impacts.

Mark Reeder, representing the Alliance for Clean Energy New York, said the final Brattle report noted that a carbon charge would induce steam unit repowering downstate, which could benefit public health by improving the air quality in New York City.

Brattle cited analysis by the ISO’s Market Monitoring Unit, Potomac Economics, that said steam unit repowering might already be economically feasible, and Tierney said they will base their assumptions on the issue on further analysis expected from the Monitor.

Renewables and Tx

The new study also will examine employment and other macro impacts of a carbon charge on New York’s economy, including reduced imports of fossil fuels.

“It is not going to be a general equilibrium model,” Tierney said. “We want to see if we can come up with a credible list of things that would be retired, or added to the system, or would otherwise have a meaningful impact on it.

“The Brattle study examined whether there would be more or fewer zero-carbon resources as a result of carbon pricing, mostly focused on nuclear,” she said, “including the enormous cost implications of” replacing the capacity and energy of those existing zero-emissions and nuclear resources, were they to retire.

“One key assumption in the Brattle analysis was that the state would simply be able to execute on its goals of putting in thousands and thousands of renewable resources,” she said. (See IPPTF Updates Carbon Charge Analysis, Treatment of RECs.) “We want to explore the role of carbon pricing in enabling the accomplishment of those important goals.”

Reeder said it would be beneficial to measure the effect of carbon pricing on the retention of existing renewable resources, such as a wind turbine with a contract that expires in 2025, and that analysis so far has not put any dollar value on the impact of carbon pricing on the deployment of energy storage, so it also “would be great to fill that gap.”

The effect of a carbon charge on nuclear revenue under 2030 reference assumptions | Brattle Group

Mark Younger of Hudson Energy Economics said that “pricing carbon would signal incentive to build new transmission, which is important if you don’t have benefits downstate without added transmission.”

Lang said he had been talking about the need for transmission for two years, and “to understand the effect of carbon pricing on building transmission would be great.”

David Clarke, director of wholesale market policy for the Long Island Power Authority, asked about the cost-effectiveness of the Regional Greenhouse Gas Initiative as an alternative model against which to assess the cost-effectiveness of carbon pricing, which he said would be a good way to measure its impact on carbon abatement.

“We did look at the revenues question, but layering on top of that the incredibly complex question of cost-effectiveness would be … somewhat outside the scope of pricing carbon dispatch,” Hibbard said.

Analysis Group will use data from the modeling runs performed for the Brattle study to assess the impact of a carbon price on demand for natural gas, Tierney said, adding that it had no plans to pursue additional Multi Area Production Simulation (MAPS) runs.

One stakeholder suggested that one or two new MAPS runs might be reasonable and cost-effective now that some base assumptions from the Brattle study are possibly out of date, including the expected in-service date of the delayed AC Public Policy Transmission projects. (See NYISO Public Policy Tx Revisions Approved.)

“I have no objections to additional data or information,” Hibbard said.

Fuel Security Study

Analysis Group also presented the preliminary outline of a study commissioned by NYISO to assess winter fuel and energy security for the New York Control Area.

Hibbard reviewed the proposed input assumptions and sources of data that would feed into the fuel security model, along with alternative assumptions and system stress scenarios. Data used are a mix of those publicly available and internal to the ISO, with preference given, where possible, to assumptions previously vetted with stakeholders.

The purpose of the analysis is not to predict the future but instead examine different scenarios, he said.

The plan is to follow up on the assumptions, data and scenarios by mid-April and present the initial findings by late April. Analysis Group will present final findings and initial recommendations in June ahead of a presentation of final recommendations in July.

NERC Conference Ponders the Human Element to Reliability

By Rich Heidorn Jr.

ATLANTA — When NERC considers a new reliability standard, it convenes drafting teams heavy on engineering expertise and system operations. But for its eighth annual Human Performance Conference last week, NERC brought in firefighters, psychologists and speakers from the airline industry to provide lessons.

“We find that all industries have people, people who actually operate the same way, whether they’re moving electrons or moving aircraft,” explained NERC Vice President and Director of Reliability Risk Management James Merlo, who served as master of ceremonies for the three-day event, co-hosted by the Department of Energy and the North American Transmission Forum (NATF).

The conference attracted more than 400 attendees from 180 organizations, including linemen, control room operators — and at least one utility billing analyst, who said he attended because his company uses root-cause analysis on billing errors.

NATF HP Assistance Visits

At the beginning of the conference, NERC CEO Jim Robb signed a new memorandum of understanding with NATF, whose 7,400 subject matter experts conduct peer reviews to promote “excellence and continual improvement.”

The nearly 90 companies in NATF operate 80% of transmission of 200-kV and higher. “It’s an impactful set of members,” NATF CEO Tom Galloway said. “If we get the forum oriented on a topic, we can typically move the ball forward pretty well.”

Representatives of MISO, Arizona Public Service and Tri-State Generation and Transmission Association shared their experiences with inviting NATF to visit.

MISO’s John Rymer, who formerly worked in transmission substation operations for Duke Energy, said he asked NATF to help transfer human performance (HP) tools from the field to the RTO’s control room. “These assistance visits really help you pinpoint where you need to concentrate your efforts,” he said.

Rymer said he is looking for “low-hanging fruit” in spreading the HP message in real-time and control-room operations first. “You can move that upstream or downstream in our organization, because engineering, IT, all these groups, can utilize the same tools,” he said.

Sage Williams, manager of Tri-State’s Eastern maintenance region, agreed. “HP can affect not just field guys. It’s your entire organization: engineering, system operations,” he said.

Sharing Mistakes, Using Technology

Digger derricks — utility trucks with augers for digging holes for poles and boom-mounted hydraulic lifts for working on wires — played supporting roles in stories by several speakers who shared mistakes they made as linemen.

In a talk titled, “How strong character improves safety and reliability,” former lineman Jeff White, now an HP consultant with Applied Learning Science, recounted how his truck flipped on its side when soft ground gave way underneath its outriggers while he was installing a pole on a new golf course.

After the crew used a second truck to get the first one back on its tires and wiped off the mud, the lead lineman told White and the other crew members not to report the incident. “‘This was a nonevent. What you just witnessed, erase from your memory.’”

White initially agreed, but after a sleepless night, he told his foreman of the incident the next day, fearful that the truck might have sustained unseen damage that could result in an injury to another worker.

“What if the bolts on that turntable — half of them are broken and we can’t see them? What if there’s factures in that steel that we can’t see? I need to speak up,” White said.

In another presentation, MidAmerican Energy displayed 3D recreations of field accidents, crafted by 3DInternet.

Mike Buntz, a MidAmerican line crew foreman, narrated an animation of a near tragedy that occurred while replacing a rotten utility pole. The truck became fully energized when its boom contacted an overhead wire, setting the grass around it on fire. Luckily, no one was injured.

“It wasn’t one of my prouder moments,” Buntz said. “But I agreed [to participate in the animation] hoping that I could help somebody down the road.”

“One of the things that we learned about using these 3D animations is it helps us to have a better appreciation of what actions made sense at the time … what happened and why,” said Sam Reno, MidAmerican’s performance improvement program manager. MidAmerican also is using GoPro cameras mounted on hardhats to produce training videos.

Peter Jackson, an HP coordinator for Georgia Power, said utilities often have “brittle systems” that assume 100% error-free performance.

He demonstrated a pilot program using visualization technology that turns an iPad into a situational awareness tool that shows real-time data on substation equipment’s health and other metrics.

Jackson said the tools can help utilities deal with the loss of experience as more of their aging workforce retires.

“We think that this really helps our guys build a deeper knowledge of the tasks and how to do it right,” he said. “We also think there’s an application potential for everything from troubleshooting to [simulations of] high-risk tasks.”

Answers from the Field

Michelle Miller and former colleague Monika Bay recounted their efforts to improve worker safety at Baltimore Gas and Electric after the electrocution of a worker at a substation.

“You can have the best intervention design in the world, but if you cannot convey it in a way that connects with the head and the heart of these front-line employees you will not be successful,” said Bay, who left BGE a year ago to start her own company, Safety & Operational Risk Solutions.

Bay said sustaining improvement “is by far the hardest part. This is really about line leaders keeping the language alive — keeping these concepts alive in their own workgroups.”

After her and Miller’s work, workers in the field started bringing risks to them, Bay said.

One such issue: the potentially fatal consequences of confusing a black, yellow-striped electric line with a nearly identical black, yellow-striped, three-quarters-inch, high-pressure, plastic gas pipe.

At BGE, gas lines are supposed to be buried 2 feet below ground, with electrical lines a foot below them. In practice, however, the lines can get transposed, meaning a worker expecting to cut a gas line could end up getting electrocuted by cutting the electric cable. The only apparent difference between the two: The gas pipe has four stripes; the electric cable only three.

“It’s 2 o’clock in the morning, I’m a gas mechanic, I’m 2 feet down in the hole, it’s raining and muddy, and I’m going to tell the difference?” Bay said.

“It wasn’t just this: We had 16 pairs of assets where the gas and electric looked very similar.”

Bay said BGE’s Executive Safety Council, which included its chief operating officer, was “horrified” by the disclosures.

“System design often puts risk into the hands of the employees,” she said. “Sometimes we don’t know some of the risk that front-line guys are dealing with because they’re just dealing with it.”

Lessons from the Airlines

Christian Vehrs of Delta Air Lines described how an aircraft maintenance employee confused a fuel heater valve with a nearly identical engine anti-icing valve because of a faulty manual and his own confirmation bias.

“These manuals are 20 years old, and we’re still discovering mistakes,” he said.

David Marx of Outcome Engenuity used dice to illustrate resilient systems. The more dice you roll, he said, the more redundancy — like setting multiple alarm clocks to prevent oversleeping.

The redundancy provided by multiple “dice” is essential in aeronautics, he said, because while Federal Aviation Administration rules require a 1 in 1 billion chance of failure, “nobody can design a part that will never fail.”

Marx used the experience of pilot Chesley “Sully” Sullenberger, who famously landed his Airbus A320 on the Hudson River when his engines failed after striking a flock of Canada geese shortly after takeoff from LaGuardia Airport in 2009.

Airline engines are expected to fail only once in every 50,000 hours. Because planes must have two engines, the chances of both failing simultaneously should be 50,0002, or 1 in 2.5 billion, Marx noted.

In Sullenberger’s case, however, LaGuardia was near a landfill that attracted birds, meaning the dice were “stuck together,” Marx said. (Airport officials increased their bird-killing programs after the incident.)

In another example, Marx cited a woman who died in 2017 after mistakenly being given a paralytic, vecuronium, instead of the mild sedative midazolam — marketed under the brand name Versed — that had been prescribed for her during a PET scan.

Hospital procedures set four “dice,” starting with an automated dispensary stocked with the drugs. A nurse mistakenly chose the wrong drug when the autocomplete function gave her options after typing the letters “V-E.”

The nurse then failed to check the drug at the dispensary or later when she delivered it to the patient. Finally, the fourth die was the nurse’s failure to remain with the patient to monitor her reaction to the drug.

“What should have been four dice became one,” he said — the active failure of choosing the wrong drug compounded by the nurse’s failure to perform the other three safeguards. The nurse is now facing reckless homicide charges.

Marx said the incident illustrated why many of us ignore speed-limit signs but slow down when we see a police car.

“We are not inherently rule followers; we are hazard and threat avoiders,” he said. “The police officer represents consequence. The sign just represents the rule.”

Lessons from the Football Field

Dave Sowers of Knowledge Vine used a video of the play known as the “Prayer at Jordan-Hare” — Auburn University quarterback Nick Marshall’s unlikely 2013 game-winning touchdown pass over the University of Georgia — in a discussion on the role of luck.

It was 4th and 18 with 36 seconds left in the fourth quarter. Auburn Head Coach Gus Malzahn called for a pass to get the first down, which would have put the team into field goal range. And the intended receiver was wide open as a second receiver went deep, drawing triple coverage. Marshall unwisely threw the ball to the deeper receiver, but two of the Georgia defenders collided, one tipping the ball into the hands of the receiver, who ran into the end zone untouched.

Marshall was lucky in that instance, but his gunslinger judgment ultimately proved his undoing, as too many of his passes ended up intercepted. “That’s why he’s not playing on Sundays” in the NFL, Sowers said. Instead, he plays for the Canadian Football League’s Saskatchewan Roughriders.

HP in the Control Room

Mohammed Alfayyoumi recounted the changes he made since becoming director of Dominion Energy’s transmission system operations center.

He spread out the workload by scheduling switching orders throughout the week rather than having them all on Mondays. He doubled the operations staff to four per shift after benchmarking Dominion’s staffing against similar-sized utilities.

He also increased simulator training, began near-miss reporting and training in root-cause analysis, and eliminated work that didn’t add value by automating 6,000 phone calls per week.

Operator hiring was improved by adding testing and screening, including more complex behavioral interviews.

“We invest a lot in steel and copper but not a lot in humans,” Alfayyoumi said. “Operator selection is vital to human performance, because you cannot fix poor selection. If you hire the wrong operator, there’s nothing you can do to make him better,” he said.

Adaptive vs. Procedural Systems

Consultant Jake Mazulewicz made the case for “adaptive” over “procedural” systems, recounting a conversation with an employee for an unnamed company who complained it had become excessively dependent on procedures.

“He said when an incident happens, even something small — someone cuts themselves with a knife, no stitches, very small stuff — everybody hears about it. And within two or three weeks you can bet your next paycheck that [the] safety and training [department] is going to say … ‘Here’s a new and updated procedure to make sure that never happens again.’

“Nobody even bothers reading the new procedures … because it doesn’t matter, because it’s going to change,” Mazulewicz continued.

Under system-based thinking, he said, “when you see an error … you don’t think who’s wrong, you think that’s a signal that my … system could use some improvement. … Almost every incident we’re talking about is triggered by human error, but it’s caused by a whole lot of other things: latent organizational weaknesses, previous decisions, things like that.

“How do you minimize errors in a system-based thinking? You improve your system. … You make it hard for people to do the wrong thing, and you make it easy for people to do the right thing.”