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November 8, 2024

BPA Stays on Track to Join Western EIM

By Hudson Sangree

The Bonneville Power Administration on Tuesday continued its series of discussions with stakeholders about joining CAISO’s Western Energy Imbalance Market, with a possible activation date in 2022.

Tuesday’s talks revolved around EIM settlements, with detailed presentations about invoices, charges and metering. The calculations may have appeared daunting but ultimately came down to familiar math, said Steve Kerns, BPA’s director of grid modernization.

“I want to make sure you don’t find this to be too scary,” Kerns told the dozens of stakeholders on the call and in BPA’s Rates Hearing Room in Portland, Ore. “There’s a lot of stuff going on here, but at the end of the day, it’s adding, subtracting [and] multiplying.”

Prior meetings that were part of BPA’s EIM stakeholder initiative have covered subjects such as market power, transmission and governance. Future meetings will deal with resource sufficiency and carbon obligations, with the next session scheduled for Jan. 16 in Portland.

BPA is targeting next September for issuing a final record of decision authorizing it to sign an implementation agreement with the EIM, which would allow the agency to begin spending on implementation projects without obligating it to join the market.

So far there has been little opposition among BPA stakeholders to joining the EIM, though details of the move are still being worked out. Joining would ease short-term trading of Pacific Northwest hydro power for solar energy from the desert Southwest and wind power from Rocky Mountain states.

BPA controls the Pacific Northwest’s largest hydroelectric resources — including the Grand Coulee, The Dalles and Chief Joseph dams on the Columbia River — and operates about 70% of the region’s transmission. Its balancing area covers most of Oregon, Washington, Idaho and western Montana, along with smaller portions of California, Nevada and Wyoming.

The Dalles Dam on the Columbia River is one of the major hydroelectric resources that the Bonneville Power Administration could bring to the Western Energy Imbalance Market. | © RTO Insider

If BPA signs an agreement with the EIM, it would bring a territory the size of France into CAISO’s real-time market. The EIM has been expanding rapidly, with entities joining or seeking to join from Canada to the Mexican border.

Idaho Power and Powerex began transacting in the market in April, bringing the number of members participating to eight. (See Idaho, Powerex Began Trading in Western EIM.) That expansion equipped the EIM to serve imbalances for about 55% of load in the Western Interconnection, according to the ISO.

NV Energy, Arizona Public Service, PacifiCorp, Puget Sound Energy and Portland General Electric are already participants.

The Energy Imbalance Market currently has seven participants in addition to CAISO. | CAISO

The Sacramento Municipal Utility District plans to begin participating in the EIM in April 2019. The Los Angeles Department of Water and Power, Arizona’s Salt River Project and Seattle City Light are scheduled to go live in April 2020. Public Service Company of New Mexico recently received state regulators’ permission to join the EIM by 2021. (See PNM Seeks to Join Energy Imbalance Market.)

In debates about establishing a Western RTO led by CAISO, the EIM often has been held up as a better alternative because, unlike an RTO, the market’s transmission-owning entities retain operational control over their assets, while member generators participate in the real-time market on a voluntary basis.

The EIM has conferred a half-billion dollars of benefits on participants since its founding five years ago, with $100 million realized in the third quarter of 2018 alone, CAISO officials said in October. (See Western EIM Reports Record Benefits.)

Moreover, the EIM’s board consists of members from multiple states, while CAISO’s board is appointed by California’s governor and confirmed by the State Senate. Industry leaders and officials from other Western states don’t want to cede control to California, and California politicians don’t want to give up authority over CAISO.

A series of CAISO regionalization measures that would have broadened its governance to include out-of-state representatives have failed in the State Legislature in recent years, largely because of this impasse. Proponents of a single RTO for the West say they will likely introduce another bill in January when California lawmakers reconvene for the start of another two-year session. (See Western RTO Proponents Vow to Keep Trying.)

In the meantime, CAISO officials and EIM participants have been pushing ahead to add day-ahead trading to the EIM’s current real-time-only market, bringing it closer to conferring many of the benefits of a regional RTO without the perceived drawbacks.

NYISO Ordered to Revise DR Meter Rules

By Michael Kuser

NYISO must revise its rules governing the installation and reading of demand response meters for participants in its Installed Capacity (ICAP) market, FERC ruled Thursday (EL18-188).

The commission partly granted NRG Curtailment Solutions’ July complaint alleging the ISO’s Tariff provisions are unjust because they require curtailment service providers (CSPs) and responsible interface parties (RIPs) seeking to participate in the ICAP market to use the services of meter service providers (MSPs) or meter data service providers (MDSPs) certified by the New York Department of Public Service to install and read non-revenue grade interval meters.

The New York PSC told FERC that the future of competitive metering services is presently in question in New York.

The ruling denied NRG’s request for waiver of the rules, instead convening a paper hearing to determine replacement provisions.

The commission found the rules unduly discriminatory to the extent they require CSPs and RIPs that are not transmission owners to be certified by the DPS, which certifies only entities that also provide metering services for the state’s retail electric market.

“The result, even if not so intended, is that retail market participation is a prerequisite for demand response resource participation in NYISO’s wholesale market,” the commission said. “Indeed, in this proceeding, the New York [Public Service] Commission disavows the role ascribed to it through NYISO’s requirements and explicitly states that its certification program was designed to facilitate retail billing service, not for participation in wholesale markets or for measuring load reductions.”

FERC noted the PSC “has issued a notice proposing to eliminate the state MSP and MDSP programs and the certifications related to these programs.”

The PSC filed comments in favor of granting NRG the relief it sought, saying “the future of competitive metering services is presently in question in New York. Upon information and belief, there are no known utility customers today who avail themselves of competitive metering services, nor have there been for some time.”

NYISO answered NRG’s complaint Aug. 13 and filed a supplemental answer Oct. 22, saying it is examining its metering requirements as part of its broader DER Roadmap. But FERC found the current metering requirements “in need of immediate remedy.”

The commission established a paper hearing with initial briefs due within 45 days of the order and reply briefs due within 30 days thereafter. It ordered parties participating in the hearing to address the following issues:

What metering requirements could be implemented in NYISO, would not be unduly discriminatory and yet would effectively evaluate, measure and verify customer meter data?

How would such metering requirements address the verification of meter data and auditing of metering service providers?

How would such metering service eligibility criteria ensure that metering services are available to customers in all geographic areas of NYISO?

Would such metering requirements allow self-certification for DR providers in NYISO? If not, please explain why.

FERC said it expects to be able to render a decision within four months of receiving reply briefs, or by May 31, 2019.

NERC Releases ‘Stress Test’ Analysis of Gen Retirements

By Michael Brooks

NERC on Tuesday warned that faster-than-expected coal and nuclear plant retirements could jeopardize reliability if grid operators are not prepared.

“If these retirements happen faster than the system can respond with replacement generation, including any necessary transmission facilities or replacement fuel infrastructure, significant reliability problems could occur,” NERC said in a special reliability assessment report. “Therefore, resource planners at the state and provincial level, as well as wholesale electricity market operators, should use their full suite of tools to manage the pace of retirements and ensure replacement infrastructure can be developed and placed in service.”

Projected retired capacity as a percent of total capacity in 2022, both currently confirmed and under NERC’s “stress test” scenario | NERC

Calling it a “stress test” of the bulk power system, the organization used data from the U.S. Energy Information Administration to identify generators set to retire through 2025 in 10 areas where coal-fired and nuclear generation make up a significant portion of the resource mix. It then analyzed the impacts of those generators retiring earlier, in 2022.

The analysis found four areas — SPP, SERC-East, WECC-RMRG and WECC-SRSG — in which currently planned generation resources would not be sufficient to make up for the accelerated retirements. NERC determined this by comparing projected planning reserve margins for 2022 under the scenario to projected peak load levels for the year. The organization used data from its 2017 Long-Term Reliability Assessment to determine projected reserve margins under currently confirmed retirements through 2022, to which it factored in the accelerated retirements. It also used the LTRA to determine the projected peak loads.

NERC analyzed the 10 regions where coal-fired and nuclear generation make up a significant portion of the resource mix. | NERC

‘Unlikely’ Scenario

Both the report and John Moura, NERC director of reliability assessment and system analysis, repeatedly emphasized that the analysis was not a prediction.

“I think it’s really important that stakeholders understand that this is a stress-case scenario,” Moura said in a conference call with reporters Tuesday morning. “We’re not necessarily making any recommendations or calls for any additional financial support beyond that which market operators think are required. We completely acknowledge that the scenario as tested is unlikely.”

He noted the organization also analyzes the impacts of geomagnetic disturbances and simultaneous, highly coordinated physical and cyberattacks on the grid. “These are things that we don’t believe will happen, but we think it’s instructive, when we break a system, to understand what are the potential mitigations and see how to get it working.”

“NERC’s stress-test scenario is not a prediction of future generation retirements nor does it evaluate how states, provinces or market operators are managing this transition,” the report says. “Instead, the scenario constitutes an extreme stress-test to allow for the analysis and understanding of potential future reliability risks that could arise from an unmanaged or poorly managed transition.”

Moura also noted that the report doesn’t criticize capacity markets or out-of-market subsidies. “We’re simply saying that these tools need to be monitored and tested in planning,” he said.

Under the “stress-test” scenario, SPP, SERC-East, WECC-RMRG and WECC-SRSG would not have enough new generation to make up for the accelerated retirements. PJM, MISO and ERCOT are just slightly above or equal to the reference levels. (SERC-East and WECC-RMRG’s margins are actually zero or in the negative.) | NERC

Fears of Politicization

NERC was criticized by some stakeholders, including FERC Commissioner Cheryl LaFleur, in early November, when it briefed its Members Representatives Committee on a draft of the report. They feared it would be politicized, and that the press and public would misunderstand it as a warning of things to come. (See LaFleur, Stakeholders Anxious over NERC Retirement Study.)

“Policymakers and regulators should not interpret this study as justifying interventions to artificially retain unprofitable power plants, as these actions deter the economic transition in the power generation fleet, undermine innovation and raise costs to America’s businesses and families,” Devin Hartman, CEO of the Electricity Consumers Resource Council, said in a statement Tuesday.

“As NERC itself states, the report looks at unlikely scenarios that go far beyond either announced or projected power plant retirements to determine at what point there might be some risk for reliability,” said Jeff Dennis, general counsel for regulatory affairs at Advanced Energy Economy. “The report does not provide evidence of any imminent threat to the reliability of the bulk power system. Nor does it suggest that competitive wholesale energy markets aren’t up to the job of ensuring reliability as the resource mix changes.”

The report “relies on too many extremes to be enlightening about real-world grid reliability,” the Natural Gas Supply Association said.

At FERC’s open meeting Dec. 20, LaFleur repeated her criticism, saying the report has a “fundamental flaw” in assuming baseload retirements beyond that currently anticipated but only counting new resource that have been announced. “So there’s an asymmetry in what’s coming out and what’s coming on,” she said. “It’s like saying, ‘What if I gave up 45% of my income and I kept my expenses the same. … You’d have a mismatch by definition.”

LaFleur said it was “noteworthy” that even under NERC’s extreme scenario “there’s not that many resource problems [that] pop up.”

“It’s a big deal … making sure we have enough resources in the future,” she concluded. “But I think we have to make sure that we rely on fact and not projections.”

NERC spokesman Marty Coyne declined to respond to LaFleur’s comments. “We don’t have anything further to say other than what’s in our media release,” he said.

Speaking to reporters after the open meeting, FERC Chairman Neil Chatterjee said he thought “NERC put a lot of work into it, and it was a thorough document. It is one data point amongst many, and I think as it pertains to our actions here at the commission and our resilience docket, my colleagues and I will analyze the myriad of data points that we have before us.”

Tuesday’s report did not include a detailed analysis of natural gas infrastructure; however, NERC said “additional midstream natural gas infrastructure could be required” to respond to early retirements.

In a November 2017 assessment, NERC had recommended industry consider the loss of key natural gas infrastructure in their planning studies under NERC reliability standard TPL-001-4. (See NERC: Natural Gas Dependence Alters Reliability Planning.)

Although NERC sees risks to increasing dependence on renewables and gas-fired generation, Tuesday’s report said that “successfully managed, the changing resource mix can provide … potential benefits to reliability and security of the BPS. Less reliance on large, centralized generation stations and greater use of dispersed networks comprised of smaller diversified generation resources can provide operating and planning flexibility. Additionally, some fuel assurance risks diminish with the changing resource mix. The effects of adverse weather on coal stockpiles or fossil fuel resupply infrastructure may be reduced when natural gas pipelines supply a greater proportion of the generating fleet. Attaining reliability enhancements associated with the changing resource mix is possible when the different challenges to fuel assurance and [essential reliability services] are addressed.”

Natural gas-fired generation’s contribution to the fuel mix in each region. | NERC

Recommendations

NERC included several suggestions to stakeholders, regulators and policymakers in the report, among them a recommendation to incorporate fuel assurance analyses in generator retirement assessments. This would mean factoring in fuel supply infrastructure, new infrastructure requirements for replacement resources, and firm vs. non-firm fuel delivery contracts.

It also recommended that regulators and policymakers consider ways to speed up approvals of infrastructure. “When a generator’s planned retirement is delayed to allow for completion of transmission system upgrades, expedited regulatory proceedings can help minimize the delay,” the report says. “Where more natural gas generation is needed, more natural gas pipeline capacity will likely also be needed.”

But Moura also noted that the report doesn’t make any specific recommendations for the four areas identified by the report as being at risk under the scenario. “We have a lot of confidence in how these areas plan their systems,” he said.

NERC Offers Upbeat Long-term Assessment

NERC Offers Upbeat Long-term Assessment

By Rich Heidorn Jr.

NERC offered a mostly upbeat report on the long-term health of the nation’s grid Thursday, celebrating results from its first interconnection-wide frequency response studies while highlighting the need to model the increasing volume of distributed resources and supplement variable generation with ramping resources.

The 2018 Long-Term Reliability Assessment, NERC’s 10-year outlook for the North American bulk power system, found that frequency response will remain adequate through 2022 despite the loss of synchronous generators and the increase in inverter-based renewables.

“That gives us some confidence in the resource mix and also the ability to … see whether that performance is degrading out in the future — which is really important, so that if there are issues, you can put [in] policies or build new resources,” said John Moura, director of reliability assessment and system analysis, during a press briefing on the report.

Moura noted that FERC Order 842, issued in February, requires all new resources seeking interconnections be able to provide frequency response, calling the requirement “really, really important for reliability.” (See FERC Finalizes Frequency Response Requirement.)

The report said dynamic stability analysis showed both the Eastern and Western interconnections’ generation “sufficiently supports frequency after simulated disturbances despite reductions in inertia” from the loss of synchronous generation. It said ERCOT has operational procedures to address risks from “degraded inertia.”

“My optimism is not only based on the current mechanisms in place but the ability of the industry to respond and adapt to the changes. And so, while today we don’t have really what I would call excellent frequency response modeling capability, we’ve got pretty good [capability]. We’re able to see it,” Moura said. “And I have confidence that we’ll be able to have that excellent frequency response model in by the time we really need it.”

Load & Reserves

The report predicts North America will see compound annual load growth of only 0.57% for summer and 0.59% for winter, with five areas — New York, New England, the Maritimes, Manitoba and the California-Mexico region (most of California and a northern sliver of Baja California) — expecting reductions in peak demand. The fastest growing regions are ERCOT and the Rocky Mountains region of the Western Electricity Coordinating Council, both projected to grow about 1.8% annually.

The report did identify concerns, noting that ERCOT’s anticipated reserve margins are below targets for the next five years, with MISO and Ontario foreseeing reserve shortfalls beginning in 2023. (See ERCOT Predicts Tight Reserve Margin for 2019.) But it said the shortfalls could be filled by accelerating construction of additional Tier 2 resources — those that have met milestones such as completing feasibility, system impact or facilities studies.

The report includes new probabilistic evaluations — loss-of-load studies that evaluate all hours of the year — which found the California-Mexico assessment area of WECC at risk of 2.3 loss-of-load hours in 2022, with an expected 152 MWh of unserved energy. “These are not significant numbers … but it’s a faint signal that tells us about risk that may not be occurring in the peak hour,” Moura said.

Following Florida, California

The report projects 100 GW of new generation in the next decade, including about 41 GW of gas and 60 GW of solar. ERCOT and the California-Mexico region expect gas generation to contribute more than 60% of on-peak capacity, while Florida expects gas’ share to rise from 70% to 80%.

“When you do have this level of natural gas resources, you have to plan differently,” Moura said. “There are things that, for example, Florida does that other areas may need to do in the future, such as procuring more firm gas … or ensuring we have more dual-fuel capabilities.”

California is leading the way in addressing reliability risks from increasing solar, with CAISO’s three-hour ramping needs hitting a record 14,777 MW last March and expected to rise to 17,000 MW by 2022.

“As solar generation continues to increase in California and elsewhere across North America, system planners should ensure sufficient flexible ramping capacity, including large-scale energy storage,” the report said.

More than 30 GW of new distributed solar PV generation is expected by the end of 2023, with California expected to reach 18 GW of capacity, almost 40% of its projected peak. New Jersey, Massachusetts and New York are projected to each have 3.5 to 4 GW of distributed solar by 2023.

“There’s more [distributed energy resources] coming online faster than we’ve really ever seen any type of resource coming on. … If that’s not represented in models, we’re going to be modeling the system completely inaccurately. And if we don’t have flexibility in our resources, we really won’t be able to meet the challenges of the daily demand curves,” Moura said.

“In areas that may not have a lot of DER, or only starting to get DER, it’s perhaps common for planning studies to negate them or net them out or mostly ignore them. However, as we get a larger penetration of DERs, it’s really important that their characteristics are modeled,” Moura said. “Engineers and planners need to prepare data specifications and data exchanges that are needed now so that we have a better understanding of what the system’s going to look like in the future.”

This fall, NERC created a new working group to guide its efforts: System Planning Impacts of DER (SPIDER).

Recommendations

Among the report’s recommendations was a call for NERC’s Reliability Assessment Subcommittee to lead development of common metrics to assess energy adequacy. “Additional analysis is needed to determine energy sufficiency, particularly during off-peak periods and where energy-limited resources are most prominent.”

Similarly, it urged NERC’s Planning Committee to develop a common framework for assessing fuel disruptions, saying “system planners should identify potential system vulnerabilities that could occur under extreme, but realistic, contingencies and under various future supply portfolios.” The assessments could be used to develop regulations or market mechanisms to promote fuel assurance.

“A common approach for what kind of contingencies to study would be very valuable to the industry,” Moura said.

Enviros Seek McNamee Recusal in Resilience Dockets

By Rich Heidorn Jr.

FERC Commissioner Bernard McNamee told Senators at his November confirmation hearing that he would consult with ethics lawyers on whether he should recuse himself from the commisison’s resilience dockets. | © RTO Insider

Environmental groups asked Tuesday that new FERC Commissioner Bernard McNamee recuse himself from the commission’s resilience dockets because of his advocacy for coal and nuclear plants during his time at the Department of Energy.

The motion by the Natural Resources Defense Council, Sierra Club and Union of Concerned Scientists echoed concerns Senate Democrats expressed during McNamee’s confirmation hearing in November (RM181, AD18-7). McNamee was sworn in on Dec. 11 after winning confirmation on a 50-49 party line vote.

McNamee’s role in DOE’s Notice of Proposed Rulemaking and the agency’s second proposal, to save at risk generators under the Defense Production Act, “create the appearance that Commissioner McNamee has prejudged central matters of law and fact that remain at issue in these proceedings,” the environmental groups wrote.

As Deputy General Counsel for Energy Policy at DOE, McNamee signed the NOPR, which asserted that “[t]he resiliency of the nation’s electric grid is threatened by the premature retirements of power plants that can withstand major fuel disruptions caused by natural or manmade disasters.” The NOPR proposed eligible fuel-secure units within PJM, NYISO, MISO and ISO-NE receive “full recovery of costs,” including a return on equity, arguing wholesale pricing in organized markets “does not adequately consider or accurately value” resiliency benefits of fuel-secure generators.

McNamee also worked on DOE’s second proposal, which asserted that “retirements of fuel-secure electric generation capacity across the continental United States are undermining the security of the electric power system because the system’s resilience depends on those resources.”

The environmental groups cited a series of court rulings outlining the circumstances in which recusal is required. “Due process considerations require that an adjudicator `who participates in a case on behalf of any party, whether actively or merely formally by being on pleadings or briefs, take no part in the decision of that case by any tribunal on which he may thereafter sit,’” they wrote, quoting from a 1958 D.C. Circuit Court of Appeals ruling.

The groups also noted FERC’s rejection of the DOE NOPR (RM18-1) is still subject to rehearing request by the Foundation for Resilient Societies. “McNamee’s participation in these rehearing requests would violate the venerable prohibition against a man standing in judgment of his own cause, and due process,” the groups said, adding that McNamee also should recuse himself from the resilience docket the commission opened in January when it rejected the NOPR (AD18-7).

‘Same Factual Questions’

“The resilience docket therefore encompasses the very same factual questions that were answered by the department, and by Commissioner McNamee on behalf of the department, in the DOE NOPR: whether the grid is threatened by retirements of so-called `fuel secure’ power plants and whether and to what extent such `fuel secure’ resources are necessary to the reliability and resiliency of the grid… The mere technicality that the two proceedings have different docket numbers, where the substantive matters at issue are materially the same, does not make the resilience docket a sufficiently distinct matter for the purposes of the due process inquiry.”

The groups cited comments filed Dec. 6 by the Harvard Electricity Law Initiative, which also questioned McNamee’s impartiality. “His recusal must extend beyond these two dockets,” wrote Ari Peskoe, the director of the law project. “The NOPR’s sweeping conclusions prejudge issues that could appear before the commission in ratemaking proceedings. This prejudgment is substantially different from a commissioner’s public statements about policy issues, which the commission has recently determined were not a basis for recusal.”

In his confirmation hearing, McNamee said he would consult ethics lawyers on whether he should recuse himself from the resilience dockets. (See Democrats Urge McNamee’s Recusal from Resilience Docket.)

Democrats also were alarmed by comments McNamee made in a videotaped speech in February after briefly leaving DOE and working for a conservative think tank’s project to “reframe the national discussion” about fossil fuels. McNamee said renewables are disruptive to “the physics of the grid” and described environmentalists’ activism against fossil fuels as a “constant battle between liberty and tyranny.”

After the video became public, Sen. Maria Cantwell of Washington, the ranking Democrat on the Energy and Natural Resources Committee, questioned McNamee in writing about his comments, asking: “How can environmental groups possibly expect a fair shake from you as a FERC commissioner?”

McNamee responded: “I understand the difference between being an advocate and an independent arbiter.”

McNamee and FERC Chair Neil Chatterjee declined to comment on the recusal motion.

Comments Filed

McNamee replaced former Commissioner Robert Powelson, who joined in FERC’s 5-0 vote rejecting the DOE NOPR and opening the new resilience docket in January. The commission has received two rounds of comments in the new docket, including a June request by FirstEnergy for an emergency order to preserve fuel-secure generating resources. (See RTO Resilience Filings Seek Time, More Gas Coordination and Don’t Rush on Resilience, Commenters Urge.) The commission has given no indication of what it will do, if anything, in response.

The Trump administration reportedly dropped DOE’s second proposal this fall. (See Chatterjee Dodges as DOE Spins on Coal Bailout.)

But the resilience concerns the department raised haven’t gone away. On Dec. 17, PJM issued a report calling for payments for fuel-secure generation. (See Full PJM Study Makes Case for Fuel Security Payments.) On Dec. 18, NERC issued a warning that quicker-than-expected retirements of coal and nuclear plants could undermine reliability. (See NERC Releases ‘Stress Test’ Analysis of Gen Retirements.)

GT Power Group’s Dave Pratzon Retiring

By Rory D. Sweeney

Dave Pratzon

It’s the end of an era at PJM: Following the Dec. 20 Markets and Reliability Committee meeting, GT Power Group’s Dave Pratzon will call it a career after 45 years.

Over that time, Pratzon has seen many of the biggest changes to the electricity industry from the trenches, having been involved in developing a number of the processes and rules that would eventually make up the grid and its markets as they are today.

“I care about the success of the enterprise. I want to deploy myself to the end,” said Pratzon, who turns 68 later this month.

A Fate-full Career

Pratzon describes his career as “an accident of fate,” or more accurately, a series of them, starting with how he got into the power business in the first place. While he went to college to become an electrical engineer, he spent his summers laboring at a local steel mill near his home in Wallingford, Conn. However, the job was threatened each year by union unrest or overproduction at the mill. He took the suggestion of a college friend from Philadelphia to join him in seeking summer employment with the Philadelphia Electric Co. (now PECO) and found himself working on substations.

Upon graduation, he attempted to land a full-time position at the utility, only to have the offer rescinded at the last moment. Scrambling, he found work near San Francisco as a field engineer for nuclear submarines. On a trip back East to propose to his  fiancée, Gail, and pick up a car,he happened to swing back through Philadelphia and stop in PECO’s offices.

“You got my letter!” a former supervisor said upon greeting the bewildered Pratzon.

“I’m just driving through,” he responded.

The boss said they were trying to contact him about a job opening and asked if he had time to interview.

“Sure,” Pratzon said, “as long as it’s today.”

The company’s response traveled faster to his West Coast home than he did.

“By the time I got there, there was the letter with my official offer,” Pratzon said.

He quit the submarine job, partially to move back closer to home but also because part of his job would have involved “sea trials” of the ships, and he realized he’s claustrophobic.

“I could never survive out there for a week or two under water in steel containers,” Pratzon said. “I was happy to come back. … It was kind of a step back to the East Coast that I figured would be another temporary position on my way back to New England.”

It would be his last major move.

“My wife and I, being New Englanders, thought this would be a temporary job before moving [back] up there, but 45 years later, we haven’t left yet,” Pratzon said.

Gail became a librarian and helped found the public library in their town, Lower Providence Township.

“Opportunities have come for both of us,” he said.

PJM Work

From his first day at PECO, Pratzon was heavily involved with PJM. PECO supplied PJM’s staff for the first several decades after its founding, and Pratzon worked for the grid operator from 1973 to 1991 before being transferred to PECO as a “broadening” assignment. He was the first secretary of PJM’s cost-development subcommittee in the mid-1970s and helped develop the initial market rules that he jokes PJM Independent Market Monitor “Joe Bowring may or may not like right now.”

Pratzon’s career was a period of change for both the industry and PJM, which began transitioning to an independent organization in 1993. In 1997, it opened its membership to non-utilities and elected an independent Board of Managers.

“The market was very different when it was just the eight companies dealing with each other,” he said, referring to PECO, Public Service Electric & Gas, Pennsylvania Power & Light, General Public Utilities (GPU), Baltimore Gas & Electric, Potomac Electric, Atlantic City Electric and Delmarva Power and Light.

The first major transition occurred during the Three Mile Island crisis, when plant owner GPU began searching for power supplies outside of the other seven utilities in PJM at the time. Up until then, the companies had bought and sold amongst each other with PJM determining which plants would run to provide all of the power necessary at the cheapest overall cost.

Each day, the companies would submit their projected costs to run each plant the following day. If one company’s plant would cost more to run the next day than those of other companies, PJM would dispatch the cheaper plant to cover the demand and charge the company with the more expensive plant half of the difference between the plants’ costs in an accounting method known as “split savings.”

But GPU’s alternative during the TMI crisis was combustion turbine plants, which were experiencing a crisis of their own during the oil shortages of the 1970s. Using the expensive CTs as the baseline cost under the split savings method would have cost GPU a fortune, so the company sought alternatives outside of the PJM ring. It was controversial and “unheard of at the time,” Pratzon said, at least partially because the other companies anticipated the profits they might make from GPU’s problems.

GPU, however, saw external tie lines that weren’t being used. “They were the first PJM utility to go out on their own,” he said.

Another blow to split savings occurred when merchant generators entered the market thanks to open-access transmission lines and subsequently refused to share their cost information.

By the time PJM began working on its locational marginal pricing proposal, Pratzon had left the grid operator and was working at PECO.

From 1992 through 2002, he advocated for PECO’s interests, including testifying at FERC in opposition to LMP. PECO at the time thought a bilateral-contracting approach would be more profitable. Pratzon was also involved with developing the wholesale market participation rules for competitive suppliers in Pennsylvania, the first state in PJM to adopt retail customer choice.

While “in the beginning, a lot of [his work at PECO] was reactionary” to what was happening in the industry, the company soon started to notice opportunities, such as selling the excess generation from its Limerick 2 nuclear plant into PJM’s markets after its failed effort to get Pennsylvania Public Utility Commission approval to include it in ratepayers’ bills.

Those experiences precipitated PECO forming a Power Team to market the excess power. “If you can’t beat them; join them,” said Pratzon, who was on the team from 2002 to 2012.

Exelon’s merger with Constellation in 2012 moved the Power Team to Baltimore. Instead of moving further from his New England roots, Pratzon lit out on his own and eventually joined with former Pennsylvania PUC Chair Glen Thomas’ GT Power Group, which already represented the PJM Power Providers group known as P3.

While Pratzon did testify at the PUC during Thomas’ tenure as the commission’s chair, they had never met.

“I don’t remember him being there; he doesn’t remember me testifying,” Pratzon said. “He heard about me through mutual acquaintances.”

Enjoying Every Minute of It

Even as his time has been wrapping up, Pratzon has remained active and vocal in stakeholder meetings.

“I’ve loved every minute of it,” he said. “It’s never the same thing twice. … I’ve invested so much of my work career into PJM and trying to help and resolve [issues].”

He hopes to have brought an attitude to the process of “trying to understand and respect the views and positions and needs of the many stakeholder groups and trying to find solutions that will help the market thrive.”

“I think … there is maybe now less of the collaborative spirit than there has been [at] times in the past. I’m not sure I can put my finger on why,” he said. “I’ll miss being part of the hopeful solution.”

PJM is a “good atmosphere to try to resolve the new issues as they come up” because while the RTO “has the hammer” to implement rules as it sees fit, it “respects and listens to stakeholder input.”

“It happens in PJM more than perhaps in any other RTO,” Pratzon said.

So why leave now?

“I feel like I have to be all-in” to do this work, he said, and to do less “would feel like dabbling.”

Instead, he’s becoming a “full-time project manager” for three months to renovate his kitchen and plans to spend more time with his three- and six-year-old grandchildren.

Traveling is in the works “to get around and see more of the world than we have in the past,” and he’ll be volunteering with an elder support group in town to meet more people and aid those who might otherwise be lonely.

Still, the stakeholder process and what it means won’t ever be far from his mind. In breaking the news of his retirement to industry colleagues, Pratzon has become fond of making a final request:

“Just remember: Keep the lights on for me now that I’m just a retail customer!”

MISO Probing South and SPP Seams Tx Needs

By Amanda Durish Cook

MISO this week opened the floor to stakeholders’ ideas on transmission projects to relieve congestion in MISO South and near the SPP-MISO seam.

During a Dec. 18 South Subregional Planning Meeting, MISO Planning Manager Matt Ellis asked for stakeholder help in identifying project candidates for the South region as part of MISO’s annual Transmission Expansion Plan (MTEP) cycle. The MTEP 19 solution submission window will close March 1.

MISO has compiled a preliminary list of four congested flowgates with upgrade potential in and around MISO South and the MISO-SPP seam, though the RTO is telling stakeholders to expect lower congestion in 2019 and beyond.

MISO Economic Studies Engineer Karthik Munukutla said several top congested areas in MISO South have already been addressed with MTEP projects, coming online as early as this month and as late as mid-2023. Munukutla also said congestion will subside due to low energy demand and potential distributed resources further reducing those needs. However, he said some local resource zones expecting high renewable penetration may experience higher congestion.

MISO predicts future flowgate congestion at the Bullshoals-Midway Jordan 161-kV line near the Missouri border in northern Arkansas and the Fulton-Patmos 115-kV line in southwestern Arkansas. The RTO also predicts seams congestion around the Raun-Tekamah 161-kV line on the Iowa-Nebraska border and the Neosho-Riverton 161-kV line on the eastern Kansas-Nebraska border.

Top congested flowgates in MTEP 19 | MISO

MISO officials said a complete list of MISO South and MISO-SPP issues and a formal request for ideas will be sent via email to stakeholders in early January.

Project ideas will be analyzed under the MTEP’s 2019 Market Congestion Planning Study (MCPS), the first such footprint-wide study since Entergy’s five-year transition period began in 2013. The transition period, which expires at the end of 2018, has limited the cost-sharing of transmission projects.

Going forward, the RTO will discontinue its practice of creating separate studies for MISO Midwest and MISO South, though the MCPS will continue to focus on subregional needs. In another first, the MCPS will also contain MISO-PJM and MISO-SPP congestion analyses that could produce an interregional congestion-relief project.

NYISO Management Committee Briefs: Dec. 19, 2018

RENSSELAER, N.Y. — Interim NYISO CEO Robert Fernandez told the Management Committee on Wednesday the Board of Directors this month had “reached a unanimous decision” on the AC Public Policy Transmission Project approved by the committee last summer and would release its decision no later than Dec. 27.

The MC in June backed joint proposals by North America Transmission (NAT) and the New York Power Authority (NYPA) to build two 345-kV transmission projects that could cost $900 million to $1.1 billion and would address persistent transmission congestion at the Central East interface and Upstate New York/Southeast New York interface. (See NYISO MC Supports AC Transmission Projects.)

Potomac Economics, NYISO’s Market Monitoring Unit, said the AC Public Policy Transmission Projects will be economic if the state Clean Energy Standard is satisfied with high levels of intermittent renewable generation upstate. | Potomac Economics

The MC selected project T027, a double-circuit 345-kV line from Edic to New Scotland, along with project T029, a standard 345-kV line from Knickerbocker to Pleasant Valley.

Winter Outlook

Vice President of Market Operations Emilie Nelson reprised the winter outlook, saying the ISO will have adequate capacity on hand to meet its forecasted peak demand of 24,269 MW for the 2018/19 winter season, well under last winter’s peak of 25,081 MW. (See NYISO Forecasts Adequate Capacity for Winter.)

Balancing Energy Tariff Revisions Okd

The MC approved Tariff changes clarifying real-time market settlements and their interaction with energy storage resources (ESRs), subject to approval by the Board of Directors in January.
ISO staffer Christopher Brown told the committee the changes do not affect calculations or require software modifications. (See “Real-time Market Settlements Clarifications” in NYISO Business Issues Committee Briefs: Dec. 12, 2018.)

Energy imbalance payments and charges address the differences among actual energy injections or withdrawals and real-time and day-ahead energy schedules. The changes apply to the injections and withdrawals of ESRs and include terms introduced and defined in the ISO’s FERC Order 841 compliance filing submitted Dec. 3 (ER19-467). (See RTOs/ISOs File FERC Order 841 Compliance Plans.)

— Michael Kuser

IPPTF Hands off Carbon Pricing Proposal to NYISO

By Michael Kuser

RENSSELAER, N.Y. — The Integrating Public Policy Task Force (IPPTF) met for the last time on Monday before handing its final carbon pricing proposal to NYISO’s stakeholder governance process. The ISO will pick up work on the market design in January through its Market Issues Working Group.

The ISO and the New York Public Service Commission created the task force last October to explore ways to price carbon into the wholesale electricity markets to align them with state decarbonization policies, including the zero-emission credit program for struggling nuclear plants.

NYISO published the IPPTF Carbon Pricing Proposal on Dec. 7 after recommending it no longer include a mechanism that would make emissions-free resources with existing renewable energy credit contracts pay the carbon component of locational-based marginal prices (LBMPc). (See IPPTF Updates Carbon Charge Analysis, Treatment of RECs.)

Social Cost of Carbon

The key metric to be used in calculating a wholesale charge on emissions is the gross social cost of carbon (SCC), which the PSC would set “pursuant to the appropriate regulatory process,” according to the proposal. The state Department of Public Service based its calculations on that of the federal government’s Interagency Working Group on Social Cost of Greenhouse Gases.

The Brattle Group projects that carbon charges will lead to incremental internal emissions reductions of 6% by 2030. Most reductions would come from price-responsive load, renewable shifts and possible nuclear retentions. | The Brattle Group

Couch White attorney Michael Mager, who represents Multiple Intervenors, a coalition of large industrial, commercial and institutional energy customers, asked whether there had been any discussions with state regulators about the timing of the PSC’s process

“I assume that the commission is not going to have any regulatory process on setting the social cost of carbon unless and until there’s a vote at the ISO, but doing it that way creates difficulties for stakeholders because then we’re being forced to vote on a carbon pricing proposal without having any guarantees on how the social cost of carbon will be set, how it will be updated [and] when it will be updated,” Mager said.

“The policy of the state of New York is very obvious, and I clearly stated where we got the social cost of carbon used in this analysis,” said Warren Myers, DPS director of market and regulatory economics. “There are no guarantees in life, but you sure have a heck of a lot of information.” (See NY Looks at Social Cost of Carbon, Modeling.)

“The ISO and DPS staff have had a few conversations on this subject” and continue to have conversations on how to structure the rules to accommodate the PSC’s ruling, said Michael DeSocio, NYISO senior manager for market design.

“At the end of the day, if there’s a public policy that establishes a value for carbon, that would be the value that we need to incorporate into the wholesale market,” DeSocio said. “How that value has been established is public policy. I don’t know that we’d create bookends for what the maximum or minimum should be.”

External Transactions

Under the proposal, suppliers would be expected to embed the carbon charge into their energy offers and would continue to receive the full LBMP and be debited their carbon charges during settlement. NYISO would calculate and publish the LBMPc to provide market transparency, adjust payments for import and export transactions, and allocate carbon residual revenues.

“As we discussed along the way, the ISO put forth a proposal that would allow imports and exports to continue to compete on a status quo basis with internal suppliers,” DeSocio said. “As we get experience with it, if we see there are ways to make it more efficient, let’s do that.”

Several stakeholders questioned how NYISO planned to deal with the possibility that FERC might not accept in full the impact of a state-mandated carbon charge on wholesale electricity rates.

“We’re looking at the potential in the very near future to have gigawatts of offshore wind coming into New England and PJM, so this concern may be on us much sooner than you think,” said Seth Kaplan of EDP Renewables. “I refer you specifically to the work done by the Massachusetts Department of Environmental Protection for implementation of the Global Warming and Solutions Act, where they got into this exact issue in terms of customers in Massachusetts that were buying clean energy and wanting to make sure that it was credited in the emissions mix.”

DeSocio said the ISO will release a forecast LBMPc an hour before real-time dispatch. “What we’re not going to do is guarantee that that forecasted price is what we’re going to charge you, and instead will charge you the actual price,” he said.

The New York Department of Public Service derived the gross SCC from the federal government’s Interagency Working Group on Social Cost of Greenhouse Gases. The expected RGGI price is based on the August 2017 base case forecast for RGGI prices (in dark blue). The light blue values are interpolated. | NY DPS

Update on Analysis Requests

DeSocio gave an update on NYISO’s actions on several stakeholder requests for additional analysis, saying it would not study using buyer-side mitigation as a replacement for carbon pricing.

“Seemingly small adjustments to assumptions have wild differences in what the analysis shows,” he said. “That tells us whatever number we put out, we know [it] will be wrong, and most likely will be wrong in a big way.”

“The reason we wanted to see this study performed is that part of the reason we’re here is because FERC is concerned with the impact state policies are having on the markets, specifically price formation,” said Matt Schwall of the Independent Power Producer of New York. “One of the tools FERC has in its box is mitigation. I don’t know what the likelihood is that FERC could subject state-supported resources to mitigation; I do know that’s an option, and that carbon pricing is one way to protect against that.”

Bob Wyman of Dandelion Energy referred to recent rulings by the PSC that will double New York’s existing 2025 storage goal to 3,000 MW by 2030 and require the state’s utilities to reduce building energy use by an additional 31 trillion British thermal units (TBtu) to meet an energy efficiency target of 185 TBtu by 2025. (See NYPSC Expands Storage, Energy Efficiency Programs.)

“It’s important to note that in that order [Case 18-M-0084], they called for 5 [trillion] Btus in savings from heat pumps,” Wyman said. “Increasing the price of electricity relative to gas and oil is going to discourage people from accomplishing that goal, as with any of the beneficial electrification stuff, if we have a single-sector carbon price. And that really should be taken into consideration.”

“Climate change is occurring, it’s clearly related to carbon dioxide emissions and it’s not tip-toeing in on little cat’s feet anymore; that time is past. It’s coming like a freight train,” Myers said. “As an economist, I am convinced that the most economical way to address this problem starts with — it may not be sufficient — but starts with a universal, economy-wide price on carbon.”

Myers said, however, that, “unfortunately, we do not currently have a federal government willing to work on such a universal, economy-wide carbon price. And the proposal we have here put forth by the NYISO is not that. Context matters, and the context here is that we are evaluating a single-state, single wholesale market carbon price.”

DeSocio said he expects stakeholders will be meeting on the carbon pricing proposal several times a month in the first half of the year and that the ISO will soon release a schedule for those meetings.

FERC OKs PJM Plan to Prevent Shortchanging of DR Value

By Rory D. Sweeney

PJM Market Implementation Committee Briefs: Sept. 13, 2017.)

East Kentucky Power Cooperative headquarters | EKPC

PJM calculates an end-use customer’s DR capability by taking the lesser of its total peak load contribution, which measures summer capability, or its WPL.

The WPL, which is usually lower, is calculated by averaging the customer’s peak hourly loads during traditional daytime hours on the five days with the highest daily unrestricted peak loads from December through February, known as the five coincident peaks (5CPs).

However, one or more of the 5CPs can have little or no load because of load-management actions, offline factories or meter malfunctions. Such reductions reduce the WPL, which will likely reduce the calculation for the resource’s potential load reduction.

To avoid this, PJM will allow customers to exclude up to two CP days when the peak hourly loads for each of those days are individually below 35% of the average peak hourly load for all the location’s winter 5CP day. The 35% threshold represents 1% of all submitted peak load days.

The commission’s Dec. 17 order said the new rules “should more accurately reflect end-use customers’ actual loads during peak winter periods.” It rejected the Independent Market Monitor’s argument that the proposal would arbitrarily increase the calculated WPL.

“Similarly, we are unpersuaded by the Market Monitor’s argument that failure to also eliminate high-load days renders the winter peak load calculation arbitrary. There is no evidence in the record that identifies any particular circumstances or events that may cause abnormally high-load days that are not representative of actual peak loads and, when used to calculate winter peak load, lead to an inaccurate representation of a demand resource’s capability to reduce its winter load.”