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November 8, 2024

PJM Monitor Reiterates Concerns in Quarterly SOM Report

By Rory D. Sweeney

PJM Independent Market Monitor Joe Bowring | © RTO Insider

PJM’s Independent Market Monitor remains unconvinced that performance metrics during localized load sheds should be used to calculate capacity market default offer caps.

Among the new recommendations in the Monitor’s quarterly State of the Market report released last week was that PJM’s capacity market default offer cap not include balancing ratios calculated for localized performance assessment intervals (PAIs) but only use PAIs triggered on at least a sub-zonal or zonal level.

The recommendation could signal the re-emergence of a fight to revise how PJM calculates balancing ratios, which went on throughout the year. At the October Members Committee meeting, stakeholders declined by the slimmest of margins endorsement of proposed Tariff revisions that would change how the RTO estimates the expected future balancing ratio used in the default market seller offer cap. That leaves PJM using its current method, which requires PAIs to perform the calculation, but the RTO hadn’t experienced any such events until this year. Though both events were very localized, PJM staff assured stakeholders they could be used for calculating the balancing ratio.

The Monitor wasn’t so sure and warned at the time that it would revisit the issue. (See “Market Seller Offer Cap Balancing Ratio,” PJM MRC/MC Briefs: Oct. 25, 2018.)

The other new recommendations included:

  • PJM should better define its rules for unit-specific parameter adjustments “to ensure market sellers know the requirements.”
  • Generators should have to request use of inflexible sell-offer segments, which should only be permitted for defined physical reasons.
  • The $7.50 margin in the definition of the cost of Tier 2 synchronized reserves should be removed because it’s “a markup and not a cost.”
  • In the calculation of the penalty for a Tier 2 resource failing to meet its scheduled obligation during a spinning event, the actual number of days since the last event greater than 10 minutes should be used instead of the average number of days between events.
  • Aggregation should not be permitted to offset unit-specific penalties for failing to respond to a synchronized reserve event.
  • Offers in the day-ahead scheduling reserve (DASR) market should be based on opportunity cost only to eliminate market power, and payments for reactive capability should be based on the 0.9 power factor that PJM has determined is necessary.
  • PJM should re-evaluate the rules governing cost-benefit analysis and cost-allocation for economic projects in its planning for generation and transmission.

The Monitor also reiterated its concern with PJM’s capacity market, giving all of the RTO’s other markets a passing grade — with caveats — for the nine months from January through September.

Resilient Grid, Resilient Market

The Monitor noted that the structure of the capacity market is not competitive because, for almost all auctions held since 2007, the results have failed the Monitor’s three-pivotal-supplier (TPS) test both within all load delivery areas and PJM-wide. The TPS test measures the degree to which the supply from three suppliers is required in order to meet the demand in a specified market.

“The outcome of the 2021/2022 [Reliability Pricing Model] Base Residual Auction was not competitive as a result of participant behavior which was not competitive, specifically offers which exceeded the competitive level,” the report said, noting that several aspects of the RPM “still threaten competitive outcomes.”

The Monitor listed replacement capacity, unit offer parameters, allowing imports to substitute for internal resources, the default offer cap and allowing demand response to substitute for capacity as ways to improve competitiveness across PJM markets.

The Monitor said energy market results were competitive, though the RTO-wide market structure was not competitive every day, and the local market structure wasn’t competitive because of “highly concentrated ownership of supply in local markets created by transmission constraints and local reliability issues.”

The synchronized reserve, DASR and regulation market results were competitive, though the Monitor criticized all three markets for also having high ownership concentrations. “A significant portion” of day-ahead scheduling offers also “reflected economic withholding,” the Monitor concluded. The regulation market design is flawed, the Monitor said, because it continues to use an incorrect definition of opportunity cost.

The financial transmission rights auction market results were competitive, though its design is also flawed, the Monitor said, because auction revenue rights are not defined clearly enough and therefore “holders cannot determine the price at which they are willing to sell rights to congestion revenue.”

The Monitor also used the report to advocate for its proposed revision of the capacity market. The issue is currently in a paper hearing before FERC. (See PJM Stakeholders Hold Their Lines in Capacity Battle.)

“The wholesale power grid is clearly resilient. The focus should be on ensuring that ongoing challenges to resilience are analyzed and addressed within a market framework. The real resilience question is whether the market construct itself is resilient. Can markets, and the market-based regulatory construct, coexist with efforts to increase the role of renewable resources through nonmarket revenue?” the Monitor wrote. “The solution must recognize that states have authority over generation and can choose to reregulate at any time.”

However, state policies are also harming markets, the Monitor said.

“Subsidies to specific resources that are uneconomic as a result of competition are an effort to reverse market outcomes with no commitment to a regulatory model and no attempt to mitigate negative impacts on competition. The unit-specific subsidy model is inconsistent with the PJM market design and inconsistent with the market paradigm and constitutes a significant threat to both,” the Monitor wrote.

The Monitor said the Sustainable Market Rule (SMR) it has proposed will “harmonize” the “three salient structural elements: state nonmarket revenues for renewable energy; a significant level of generation resources subject to cost of service regulation; and the structure and performance of the existing market-based generation fleet.”

“Harmonizing means that the integrity of each paradigm is maintained and respected. Harmonizing permits nonmarket resources to have an unlimited impact on energy markets and energy prices. Harmonizing means designing a capacity market to account for these energy market impacts, clearly limiting the impact of nonmarket revenues on the capacity market and ensuring competitive outcomes in the capacity market and thus in the entire market,” the Monitor wrote. “The expected impact of the SMR design on the offers and clearing of renewable resources and nuclear plants would be from zero to insignificant. The competitive offers of renewables, based on the net ACR [avoidable cost rate] of current technologies, are likely to clear in the capacity market. The competitive offers of nuclear plants, based on net ACR, are likely to clear in the capacity market.”

PJM PC/TEAC Briefs: Nov. 8, 2018

By Rory D. Sweeney

Renewables’ Capacity Analysis Extended

VALLEY FORGE, Pa. — PJM is planning to hold a special session of the Planning Committee to further discuss the RTO’s effective load carrying capability (ELCC) analysis for wind and solar resources, staff told attendees at last week’s Planning Committee meeting.

Stakeholders at the November meeting of the Planning Committee discuss issues. | © RTO Insider

The analysis was originally developed to justify PJM’s plan to calculate wind resources’ capacity credits using the median — instead of mean — performance of wind units over peak summer hours. However, substantial stakeholder examination spurred PJM to schedule a separate meeting on the issue. It is tentatively scheduled for 9 to 11:30 a.m. on Nov. 26.

“These are great options to have on the table, but until we know what we’re going to do with them … these probably should just remain as options,” said Carl Johnson, who represents the PJM Public Power Coalition.

He noted the volatility of the analyses.

“I’m still trying to figure out what they mean,” said John Brodbeck, who represents EDP Renewables. “I don’t know what we’re going to do with this.”

PJM’s Patricio Rocha Garrido explained that the analysis is a measure of the additional load that the system can supply with the analyzed generators without a change in reliability. The results are driven by the output of the generators during hours with potentially high reliability risk.

PJM’s Tom Falin noted that the ELCC addresses saturation, so as wind penetration increases, the ELCC value incrementally goes down in percentage.

DER Ride-through

Stakeholders approved a problem statement and issue charge to implement a new Institute of Electrical and Electronics Engineers standard on how distributed energy resources should react to system voltage fluctuations.

PJM’s Emanuel Bernabeu explained that the scope of the investigation won’t include voltage regulation or communications, won’t go beyond discussions of the distribution system and won’t be retroactive.

Dynamic Models

PJM’s Tao Yang and Kyle Clifford | © RTO Insider

PJM wants to eliminate use of dynamic models that NERC finds unacceptable and reduce the use of user-defined models (UDM) by promoting generic models, PJM’s Tao Yang and Kyle Clifford said.

The RTO also wants to improve the quality and usability of remaining UDMs, so generators will have to provide evidence to support use of their preferred UDMs if the applicable generic model’s accuracy and performance is not satisfactory to represent the dynamics of the device. Generic models have advantages of reducing conflicts and debugging time but also might not capture state-of-the-art technology.

For existing generators, the unacceptable UDMs will be phased out via improved requirements to three NERC specifications, which will be presented at the PC in the spring.

The change will take effect for planned units in the AF1 interconnection queue, where impact studies must use generic models with minimal exceptions.

The plan concerned some stakeholders. It’s “already a traumatic event to get turbine models” approved, Brodbeck said.

“We’re not opposed to all user-defined turbine models,” PJM’s Susan McGill said, but staff want to see them ahead of time.

The changes are not a manual change but instead mean better enforcement of using the dynamic model agreement in Manual 14G, she said.

Generation Deactivation

PJM’s Jason Connell | © RTO Insider

PJM’s Jason Connell announced during the Transmission Expansion Advisory Committee meeting that FirstEnergy Solutions has asked to accelerate deactivation of the three units of its 2,490-MW Bruce Mansfield coal-fired plant from June 2021 to February 2019.

Additionally, two other facilities in the ATSI zone have requested deactivation on June 1, 2021: the 24-MW Eastlake 6 and 2,160 MW at Sammis’ Units 1 through 6, as well as its 13-MW diesel unit.

The 9.4-MW Kimberly Clark plant in the PECO zone has requested deactivation on Aug. 1, 2019.

The deactivations precipitate several baseline transmission projects to ensure reliability, but the accelerated deactivation requires accelerating only one transmission project. One project is in both Duquesne Light and Allegheny Power Systems, five are in Duquesne alone, three are in ATSI, one crosses ATSI and APS, 10 are in APS, four are in Penelec and one is in AEP.

Dominion Solutions

Dominion Energy presented planned solutions for another eight of the supplemental projects it has brought to the TEAC as part of the transmission owners’ new FERC-ordered process for developing supplemental projects. Dominion has presented 19 needs assessments since the process was implemented in September.

The new solutions are projected to cost roughly $13.1 million.

The company presented two solutions at October’s meeting. (See “Dominion Supplementals,” PJM PC/TEAC Briefs: Oct. 11, 2018.)

PJM Operating Committee Briefs: Nov. 6, 2018

By Rory D. Sweeney

Winter Weekly Reserve Target Recommendations

VALLEY FORGE, Pa. — Stakeholders at last week’s Operating Committee meeting endorsed PJM’s recommended winter weekly reserve targets, which consist of monthly values based on weekly peak load and will be used to schedule outages over the winter.

The analysis calculated maximum available reserves of 22% for December (compared to 23% last December), 28% for January (27%) and 24% for February (25%). The values are incorporated into PJM’s annual Reserve Requirement Study, which also calculates the installed reserve margin and the forecast pool requirement.

PJM’s Patricio Rocha Garrido | © RTO Insider

PJM’s Patricio Rocha Garrido noted that the majority of the winter reliability risk is in January, which is reflected in the higher target value in that month.

Day-ahead Scheduling Reserve Recommendation

Stakeholders also endorsed by acclamation PJM’s calculation for the 2019 day-ahead scheduling reserve (DASR) requirement of 5.29%. It will be incorporated into Manual 13 and implemented on Jan. 1. The 2019 DASR requirement is a 0.01-point increase from the 2018 requirement of 5.28%.

The DASR requirement is composed of the load forecast error (LFE) and forced outage rate (FOR), which are determined on a seasonal basis first and then annualized to express average LFE and FOR rates for the year. The LFE and FOR components for 2019 are 2.18% and 3.11% respectively.

Generator Voltage Schedule

The committee endorsed revisions to both Manual 3 and Manual 14D, including an update to the generator voltage schedule with new processes that require TOs to verify and submit voltage schedules via eDART, generation owners to review the schedules and the eDART contact to acknowledge the schedule. This will all need to be done annually.

Resource Tracker

PJM’s Rebecca Stadelmeyer | © RTO Insider

PJM’s Rebecca Stadelmeyer presented the results of a stakeholder survey and a first read for revisions to Manual 14D that would create a new Section 5.3.7 outlining the timeline for confirming generator data in Resource Tracker each year. The survey found that the “overwhelming desire” was for a four-week window from Oct. 1 to Nov. 1, Stadelmeyer said.

Resource Tracker was created in 2013 to provide a single mechanism for resource owners to submit generator information, namely information regarding ownership, ownership changes, the bidding company and dispatching company.

Additionally, PJM is planning to update Resource Tracker by the first quarter next year with improved formatting, additional data and updates to the user guide. Updates on these initiatives will be provided to the Tech Change Forum and the System Restoration Coordinators Subcommittee.

Uneventful Month Operationally

There was one spinning event and one high system voltage action in October, fairly routine operations for the month, according to PJM’s operations report.

“The month was uneventful,” PJM’s Mike Zhang said.

The average RTO LFE in October was 1.93%, which was within the 3% goal, and other metrics were “pretty on par” with the same month a year ago.

GT Power Group’s Dave Pratzon noted that the quarterly average peak LFE for the ComEd zone has followed a pattern during the past three years of meeting or exceeding PJM’s 3% target goal in the third quarter. RTO staff could not explain the pattern, but took an action item to analyze it and report back at a subsequent meeting.

Order 841 Compliance

PJM’s Andrew Levitt | © RTO Insider

PJM’s Andrew Levitt provided a status report on the RTO’s proposal to comply with FERC Order 841, which is due by Dec. 3 and will define electric storage resources (ESRs) and alter some market rules to accommodate ESR participation.

Levitt explained PJM’s understanding of FERC’s descriptions of different types of setups and charging energy. The order defines an ESR as “a resource capable of receiving electric energy from the grid and storing it for later injection of electric energy back to the grid.” An ESR can be connected at the transmission level, distribution level or behind the meter.

The filing will also distinguish between charging energy purchased by ESRs that is intended for resale as wholesale or retail. Currently, all charging for any ESR capable of serving end-use load is purchased at retail. Energy for retail resale would need to be purchased through a load-serving entity (LSE) and would not be PJM-jurisdictional, while energy intended for wholesale resale could be purchased from and sold back to PJM and would be under FERC’s jurisdiction.

Implementation will occur in 2019 and include methods for resource categorization and coordination with utilities.

Primary Frequency Response Moving Forward

PJM’s Glen Boyle explained that, in light of FERC’s clarification on Order 842 issued on Aug. 24, the Primary Frequency Response Senior Task Force has moved forward. (See PJM Gens Pitch Order 842 Compliance Plans.)

“We’ve been on kind of a mini-hiatus while we waited for some FERC clarification. We have received that,” Boyle said.

Final proposals are due on Nov. 21, with final review at the task force’s next meeting on Nov. 27. A subsequent poll on the options will be open until Dec. 3, with staff targeting the task force’s Dec. 5 meeting to review results.

Preliminary data at the task force’s last meeting showed about 50% of resources not meeting performance criteria, though some did provide very good response. Boyle said the cause of the poor performance is still unknown, but that staff are working with owners to figure out how to fix it.

Dominion Gone Until May

PJM’s Lagy Matthew said there is only one significant extended transmission outage expected this winter. The Dooms-Cunningham 500-kV line in Dominion’s zone will remain on outage for all but three days until May 3. It is related to an end-of-life rebuild expected to be complete in June 2019.

The outage may cause low voltages and minor thermal overloads in the area but no reduction to generation capacity because of stability issues.

Dispatch Signal Survey

PJM is planning to distribute a survey to dispatchable resources on Nov. 26 to determine units’ ability to follow electronic dispatch signals, Zhang said. Deviations from the signal can cause financial penalties and dispatch issues, he said. PJM hopes to determine whether units can follow dispatch verbally or electronically and understand other signal-following limitations.

The goals are to improve the security-constrained economic dispatch (SCED) solution with more accurate expectations, enhance synchronized reserve allocation and deployment, and potentially overhaul tools to better reflect generation fleet characteristics.

PJM is gathering the responses because it doesn’t have a centralized mechanism for updating existing information.

“Understanding that there are some changes coming, it’s definitely good to get ahead of the situation,” Zhang said.

Generation Lifts NRG Energy Q3 Earnings

By Michael Kuser

NRG Energy earned $306 million last quarter, up 65% from the same period a year ago on strong returns for the company’s generation business.

The generating arm pulled in $595 million, compared with $272 million a year earlier, but fluctuating prices in Texas and California squeezed the company’s retail business, which posted a loss of $127 million for the quarter.

CEO Mauricio Gutierrez said during a Nov. 8 earnings call that he was “pleased with the operational and financial performance of our integrated platform during a period of extreme price volatility. … During periods of high prices, our generation business benefits while our retail business experiences some margin compression.”

The company presentation highlighted the closing on the sale of NRG Yield and its Renewables platform as a milestone. It also announced an incremental $500 million stock repurchase in addition to the $1 billion announced earlier in the year, bringing total share repurchases to $1.5 billion.

Gutierrez said NRG expects to close on the sale of its 3,555-MW South Central portfolio of generation assets in Texas by year-end and the sale of its 500-MW Carlsbad Energy Center in California in the first quarter of next year.

(Top) Peak load growth remains strong in ERCOT. Peak load growth remains strong in ERCOT. (Bottom) ERCOT power prices came in lower than forwards because of near-perfect generator performance. | NRG

Price Volatility and MOPR

Warmer-than-normal weather across the company’s core markets led to higher demand last quarter, particularly in Texas, which set a new record peak load of 73 GW. Despite robust loads, actual prices were mixed across markets compared with expectations, with real-time prices in ERCOT coming in significantly lower than projected.

A combination of near perfect performance by generators during the July heat wave and milder temperatures in August resulted in prices 77% lower than expected at the beginning of the summer, Gutierrez said.

He noted that most of the current reserve margin in Texas is made up of capacity from renewable generation — non-dispatchable capacity that could potentially lead to fluctuations in the actual amount of generation available to serve load.

The California market was a different story, with prices settling well above expectations, mainly because of restricted gas deliverability, he said. The combination of once-through cooling unit retirements and the emergence of community choice aggregators have resulted in recent increases to Western capacity prices.

In the East, energy prices were pretty much in line with expectations, and the company’s focus is on both capacity and energy market reforms, Gutierrez said.

“As you know, FERC has stated that the existing capacity market in PJM is unjust and unreasonable, due to the negative impact of subsidized units,” Gutierrez said. “Let me reiterate that we believe a strong MOPR [minimum offer price rule] is the simplest and most effective way to reduce the harmful impact of subsidies on the capacity market.”

PJM and ISO-NE also are working on fuel security, which should lead to additional revenues for generators that have on-site fuel capabilities, he said.

“This is very much at play, but all these regulatory changes are designed to improve the current status quo and are positive for our portfolio,” Gutierrez said.

Call transcript courtesy of Seeking Alpha.

PJM Market Implementation Committee Briefs: Nov. 7, 2018

By Rory D. Sweeney

GreenHat Default Update

VALLEY FORGE, Pa. — PJM’s Brian Chmielewski told attendees at last week’s Market Implementation Committee meeting that the Board of Managers’ investigation of the GreenHat Energy financial transmission rights default will run through the new year, with a report and recommendations to follow.

Stakeholders at the November meeting of the Market Implementation Committee discuss issues. | © RTO Insider

There will updates on a roughly weekly basis, CFO Suzanne Daugherty said, suggesting Thursday as the best day for stakeholders to look for them.

The default is expected to become the largest ever in PJM’s FTR market and has spurred RTO policy changes to limit the risks that allowed it to occur. The RTO recently filed a lawsuit in Texas in an attempt to recoup some payments the defaulting company promised but never delivered. (See GreenHat: (Some of) the Rest of the Story.)

Day-ahead Market Timeline Manual Changes

Stakeholders approved by unanimous acclamation changes to the day-ahead deadlines described in Manual 11, made possible by improved computing ability. PJM’s Keyur Patel explained that market participants will have until 11 a.m. to submit day-ahead bids and offers, and the clearing window will be reduced to 2.5 hours. The deadline for posting day-ahead results will remain at 1:30 p.m. or as soon as practicable thereafter.

While the overall proposal has already been approved by PJM’s Markets and Reliability Committee, the manual changes have not yet been addressed. (See “Day-ahead Market Timeline,” PJM MRC/MC Briefs: Oct. 25, 2018.)

PJM’s Tim Horger said implementation will likely occur in mid-December to make sure all market participants are aware of the changes. Staff confirmed that they planned to file the changes at FERC on Nov. 8.

Must-offer Exception Changes

Stakeholders chose PJM’s proposal over a proposal from the Independent Market Monitor for changing the rules describing how capacity resources secure exceptions to their requirement to offer into capacity auctions. (See “Must-offer Exception,” PJM Market Implementation Committee Briefs: Oct. 10, 2018.)

The PJM proposal received 0.79 in favor in a vote that had a 0.5 threshold, while the Monitor’s package received 0.22 in favor. PJM’s proposal was also preferred 0.78 over the status quo.

PJM’s Susan McGill explained the RTO’s rules for how capacity interconnection rights (CIRs) can be transferred and the impact on projects in the interconnection queue. PJM’s Pat Bruno reviewed the RTO’s proposal.

Monitoring Analytics’ Alexandra Salaneck | © RTO Insider

Monitoring Analytics’ Alexandra Salaneck summarized the Monitor’s alternative proposal, which would remove the ability for a unit to request that it retain its capacity resource status as late as 135 days prior to an impending status change to becoming an energy-only resource. The change would have basically allowed resources to get an exception from just one Base Residual Auction, Salaneck explained.

“What we’re trying to prevent is flip-flopping out of and back into [the Reliability Pricing Model],” she said.

Gary Greiner of Public Service Enterprise Group questioned the need for removing that provision.

“I understand the process to be quite rigorous when someone asks for a must-offer exception,” Greiner said. “We’re in a dynamic business environment. There are a lot of reasons” why the provision might be necessary.

The Monitor’s idea struck a chord with Dave Mabry, who represents the PJM Industrial Customer Coalition. He said the “jumping in and out” of BRAs might cause approved transmission projects to become unnecessary.

“I think we’re leaning toward the IMM proposal,” he said.

FTR Forfeiture Proposal Endorsed

Stakeholders endorsed a proposal developed by Exelon, NextEra Energy and VECO Power Trading over an alternative proposed by PJM to revise the RTO’s rule on when FTR profits should be forfeited. (See “FTR Forfeiture,” PJM Market Implementation Committee Briefs: Oct. 10, 2018.)

The joint proposal received 0.85 in favor in a vote that had a 0.5 threshold and 0.74 in favor compared to the status quo. PJM’s proposal originally received 146 votes in favor, or 0.53, and would have exceeded the 0.5 threshold, but staff announced after the vote had been recorded that a participant informed staff in a timely fashion that it had submitted its 14 votes incorrectly. They were changed to oppositional votes, leaving the proposal with 132 votes in favor, or 0.48, and just below the threshold.

Monitoring Analytics’ Seth Hayik | © RTO Insider

Monitoring Analytics’ Seth Hayik presented concerns the Monitor has with changing the rule and reiterated its preference for the existing penny test, which focuses on the actual impact of virtual trades on FTR profits rather than the traders’ intentions.

“We can’t prove intent; we can’t measure intent,” Hayik said. The existing rule is “meant to deter [manipulative behavior] and to catch it,” he said.

The joint proposal’s impact test would have a threshold of FTR flows greater than or equal to 10% across a constraint.

Gabel Associates’ Mike Borgatti, who represents NextEra, agreed that such behavior needs to be eliminated, but that the current rule is too strict for market participants to risk using virtual trading for fear of triggering forfeitures. He said PJM and the Monitor should be able to monitor and take actions against bad behavior, and that being unable to determine intent is “not a sufficient basis to justify a rule” that impedes use of the products.

Stakeholders and the Monitor also battled over the implications of a graph that showed reduced forfeitures since the rule has been in place.

“The only thing we can conclude is that hopefully the feedback is working,” Hayik said.

“That graph is just showing that we have stopped virtual trading,” Exelon’s Sharon Midgley said.

Greiner concurred that PSEG’s use of virtual products has also “dropped precipitously.”

“We have virtually stopped using this as a hedging tool that we used pretty consistently prior to recent changes,” he said.

PJM’s Chmielewski said it’s unclear yet whether the RTO will pursue rebilling if the proposed changes are implemented.

Gas Pipeline Contingencies

Stakeholders endorsed a Calpine proposal over several alternatives on compensating generators who are switched from their preferred gas pipeline because of pipeline contingencies identified by PJM.

Calpine’s proposal received 0.75 in favor on a vote with a 0.5 threshold and 0.99 in favor over the status quo. PJM’s alternative received 0.42. Direct Energy’s proposal received 0.42, and a proposal developed at the meeting to merge elements of the Calpine and Direct Energy proposals received 0.4 in favor.

The Calpine proposal would provide a broader scope of factors and time for which a unit can recover costs during and after a PJM fuel-switch directive. Direct Energy’s proposal would have allowed generators to receive “a just and reasonable rate” that would be treated as balancing operating reserves.

Direct Energy’s Marji Philips said she was frustrated that PJM had decided to direct generators on what fuel sources they must use, but because the policy exists, there “should be some compensation.”

“I don’t believe PJM should be directing an entity to switch fuels,” Philips said.

She argued that the new policy would create more payments for issues that are supposed to be paid for by PJM’s Capacity Performance rules.

Analyses Show Flat Emissions Under NY Carbon Price

By Michael Kuser

RENSSELAER, N.Y. — New York electricity market stakeholders on Friday reviewed three separate studies to evaluate the implications of a carbon charge in NYISO’s energy markets.

The reports by the Brattle Group, Daymark Energy Advisors and Resources for the Future (RFF) find similar reductions in systemwide carbon emissions from a carbon charge: less than 1 million metric tons, according to the ISO’s synthesis of the studies

Michael DeSocio, the ISO’s senior manager for market design, told the Integrating Public Policy Task Force (IPPTF) Nov. 9 that “all the analyses were generally supportive of each other.”

All three studies isolate the effects of a carbon charge by modeling both a “base case” without carbon pricing and a “change case” with carbon pricing, but they each differ in the years evaluated. The Brattle study evaluates effects in 2020, 2025 and 2030, while Daymark’s analysis evaluates 2021-2025, 2030 and 2035. The RFF analysis focuses solely on 2025. (See NY Details Carbon Charge on Wholesale Suppliers.)

NYISO
Daymark Energy Advisors’ projected carbon emissions under a New York carbon pricing policy. | Daymark

Analytical Results

Daymark’s Marc Montalvo said that his group’s study found that “carbon emissions in New York are about flat. There’s not really a material change as a consequence of the introduction of the carbon charge.”

RFF’s Dan Shawhan said his group’s updated results show “a CO2 emissions reduction of 0.2 million tons in the simulated year, which is 2025, and that’s about 0.65%, so about two-thirds of a percentage point reduction in New York emissions. And I don’t disagree with the characterization that you could describe that as not a big change in emissions.”

Brattle’s Sam Newell agreed and said “a lot of what’s happening here is we’re comparing to a base case that already has in place the Clean Energy Standard and other mechanisms to reduce emissions.”

But both the RFF and Brattle studies say that a carbon pricing policy can also be expected to reduce emissions in ways not captured in the modeling.

The carbon charge is another way of accomplishing decarbonization with more dollars put toward a market-oriented approach, and less money relying on targeted programs, Newell said.

“In both cases there’s decarbonization, so it’s not a surprise that there’s not some major change in carbon with the introduction of this policy,” Newell said. “Directionally it’s going to be an improvement because it finances some low-cost forms of carbon abatement, and there are probably some long-term investment effects.”

All studies find higher statewide locational-based marginal prices resulting from a carbon charge, with increases most significant downstate. The Brattle analysis finds LBMPs would rise by less than the Daymark and RFF studies.

Differences in LBMP changes can be at least partly explained by differences in each study’s modeling of the market heat rate, and also in part by assumptions regarding the net social cost of carbon in each study, the ISO’s summary said.

The studies assume similar carbon charges through 2025, but the Daymark study finds LBMP impacts would increase from 2025 to 2035. In contrast, Brattle finds lower carbon charges in 2030 than 2025 because of assumed increases in the Regional Greenhous Gas Initiative price, resulting in carbon charges of $45.40/ton in 2030, compared with $57/ton in 2030 assumed by Daymark.

Brattle and RFF both find collected carbon revenues on the order of $1.5 billion per year; Daymark finds declining carbon revenues, falling from $1.4 billion in 2021 to $1 billion in 2035.

Stakeholder Requests

DeSocio presented an update on NYISO’s progress in meeting stakeholder requests for further analysis on certain points.

Analysis is under way on augmenting the Brattle analysis with 2022 results and considering the effects of carbon pricing on repowering and retention, and should be ready for discussion at the Nov. 26 task force meeting, he said.

The ISO also said it does not recommend following a stakeholder suggestion to lower the 2030 RGGI price estimate because such a move is not supported by analysis based on results provided to date, DeSocio said. As RGGI is adjusted downward both with and without carbon pricing, the other parts of the analysis approximately scale. Because the overall impact is near zero, the scaled impact is near zero.

To consider the consequences of no carbon pricing, including estimates of the costs of various buyer-side mitigation scenarios, and the consequences of NYISO’s AC transmission project in western New York, the ISO is still considering how it might structure such analyses and will update the IPPTF at its next meeting, he said.

Regarding the effects of a carbon charge on existing renewable energy credit contracts and future REC contracts, DeSocio said, “In our analysis to date, we are not suggesting that REC contracts go away. Certainly the price of a REC contract may go down because the carbon price is being realized and therefore the delta payment that a renewable resource is getting is less, but in the analysis so far, we haven’t shown that to go to zero.” (See NY Carbon Task Force Looks at REC, EAS Impacts.)

The Daymark study does not evaluate changes in REC and zero-emission credit prices stemming from a carbon charge, but it finds the following gross profit margin (revenue minus fuel costs) average increases: upstate nuclear plants 70%; upstate solar 48%; upstate wind 46%; downstate offshore wind 47%; and downstate solar 51%, according to the ISO synthesis.

The RFF analysis finds the carbon charge would reduce REC prices from $43/MWh to $24/MWh and would reduce ZEC prices from $14/MWh to $0/MWh in 2025.

The Brattle analysis finds the carbon charge would reduce ZEC prices from $25/MWh to $12/MWh in 2025, while REC prices would fall from $22/MWh to $3/MWh in 2020, $25/MWh to $7/MWh in 2025 and $28/MWh to $12/MWh in 2030.

The task force next meets on Nov. 26. It plans to announce a proposal to incorporate carbon pricing into the state’s wholesale market next month.

OGE Beats Expectations with Q3 Earnings

By Tom Kleckner

OGE Energy beat expectations last week, reporting third-quarter earnings of $205 million ($1.02/share), up from a year ago, when it earned $183 million ($0.92/share).

A Zacks Investment Research survey of analysts had projected earnings of 96 cents/share.

“Good companies grow, and that is clearly what we are doing,” CEO Sean Trauschke said during a Nov. 8 conference call with analysts.

OGE’s regulated utility, Oklahoma Gas & Electric, contributed 92 cents/share during the quarter, thanks to new rates in Oklahoma, favorable weather and increased customer demand.

OG&E crews at work | OGE Energy

The Oklahoma City company also received earnings of 14 cents/share from Enable Midstream Partners, a gas-gathering and processing joint venture with Texas utility CenterPoint Energy.

Enable said Nov. 7 that it processed record amounts of natural gas during the third quarter. OGE holds a 25.7% limited-partnership interest and a 50% management interest in Enable, while CenterPoint owns a 54.1% share.

OGE increased and narrowed its year-end guidance to $1.59 to $1.61/share, up from $1.43 to 1.53/share.

OGE shares finished the week at $38.08/share, up almost 16% since the beginning of the year.

CenterPoint Earnings Drop 4 Cents

CenterPoint reported third-quarter earnings on Nov. 7 of $153 million ($0.35/share), a drop from a year earlier, when it earned $169 million ($0.39/share).

Revenues totaled $2.2 billion, up from $2.1 billion a year ago, thanks to increased rates and a growing customer base.

CenterPoint Energy
CenterPoint Energy EV | CenterPoint Energy

CEO Scott Prochazka told analysts during a conference call that the Houston-based company in October completed the equity and fixed rate debt components of the financing for its $6 billion acquisition of Indiana utility Vectren. Prochazka said the acquisition is still expected to close in the first quarter of 2019 and has targets in place “that are in line” with an $50 million to $100 million in pretax earnings by 2020.

CenterPoint’s share price lost 51 cents following the earnings announcement, finishing the week at $28.16.

New England Talks Energy Security, Public Policy

By Michael Kuser

MARLBOUROUGH, Mass. — Can New England balance reliability, economics and public policy in a fast-changing energy world? How will the region better prepare itself to handle winter cold snaps than in the past?

These and other questions arose at the Northeast Energy and Commerce Association’s 17th Power Markets Conference on Nov. 8. Here are highlights of what we heard.

NECA
The Northeast Energy and Commerce Association held its 17th annual Power Markets Conference on Nov. 8. | © RTO Insider

Internalize, Don’t Politicize

NECA
Ashley Brown | © RTO Insider

Ashley Brown, executive director of Harvard University’s Electricity Policy Group, said, “My fear today is that we’re moving back to a battle between various special interest groups and further politicizing the sector.”

Resource selection based on economics, reliability and social benefits has given way to state subsidies and mandates that often work against public policy environmental goals, with uneconomic resources chasing bailouts instead of focusing on how to become more efficient, he said.

“Part of the problem … is that we have simply failed to internalize social considerations in economics,” Brown said. “The lack of a carbon policy in the U.S. is not only intellectually bankrupt, but it does in fact penalize emissions-free resources.”

Energy Security Banking

Mark Karl | © RTO Insider

Mark Karl, ISO-NE vice president for market development, said the region is moving into an era in which more resources have less fuel security. The grid operator is concerned the situation will get worse.

Fuel logistics become an issue in winter, whether because of natural gas pipeline constraints, limited dual-fuel storage or reduced ability to deliver oil by truck, he said. The significant retirement of large non-gas-fired generation is an important factor, as is the type of oil used.

“For example, some generators are burning No. 6 oil, which is basically almost asphalt, so in the wintertime, when that stuff gets cold, it gets pretty difficult to pump and move,” Karl said.

The retirement of two nuclear plants and the Brayton Point coal plant in recent years might be good for the environment, but collectively it presents a challenge for reliability, he said.

Karl said ISO-NE is looking to create a new reserve service referred to as “the energy inventory reserve constraint.”

“We’re proposing to incorporate into the real-time market an additional constraint that looks at the ability to provide energy storage or an energy bank,” he said. “I want to be careful here because it’s easy to think about this from the standpoint of conventional generator fuel, but this will apply to any sort of resource that has the ability to maintain essentially a reserve bank of energy that can be converted into electricity when needed.”

The idea is to optimize the use of limited energy over more extended periods compared with how markets are currently designed to optimize energy over the course of an operating day, he said.

Outside the marketplace, operators also worry about the next day and the days that follow, and sometimes order an oil-burning unit offline for a weekend anticipating the need to provide reserves come Monday, “so that’s an out-of-market action that does cause distortions in the marketplace,” Karl said.

Market Reaction

Brett Kruse | © RTO Insider

Brett Kruse, vice president of market design at Calpine, said ISO-NE could use a six- or seven-day-ahead market to effectively manage storage in a way that avoids having to take out-of-the-market actions.

The proposal could help the RTO manage how it deploys plants day to day and provide an insurance policy to keep a certain amount of storage in the system, he said.

“There are a lot of questions about that and how it would be priced, but it’s conceptually a pretty good idea,” Kruse said.

But he also had some reservations about the plan. “Looking at the way they’re presenting it now, where it’s a voluntary forward market, and won’t have any mitigation, which is a key aspect to go with that, we think it has some potential, although it’s hard to see how a lot of load will come into that,” he said.

NECA
NECA energy security panel (left to right): Abigail Krich, Boreas Renewables; David Cavanaugh, Energy New England; Brett Kruse, Calpine; and Matthew Picardi, Shell Energy. | © RTO Insider

David Cavanaugh | © RTO Insider

David Cavanaugh, vice president of regulatory and market affairs for Energy New England, an energy services firm, said the RTO’s thinking at first glance seems robust, as its design extends beyond the winter period into a period where the bulk power system has more renewables and, perhaps, storage resources.

“I’m not sure the sophistication of this model gets us there … but we can be informed by other interim efforts such as the opportunity cost model set for use this winter,” Cavanaugh said. “I think the design is well thought out … just have some concerns when I look at the multi-day-ahead market, its voluntary participation,” in terms of maintaining adequate fuel stocks.

Abigail Krich | © RTO Insider

Abigail Krich, president of Boreas Renewables, said she sees a market design that, “even though it was triggered by fossil fuel issues, could work with that transition to a clean energy system that relies on intermittent generation. It looks like something that makes sure we have a dispatchable store of available energy in reserve.”

“I question whether we need all of these pieces in the proposal or whether we might just use some of them,” Krich said.

Public Policies

Discussing the race for renewables at the state level, Peter Fuller of Autumn Lane Energy Consulting said the tension in these markets is understandable. While consumers have benefited greatly from the markets, and investors and market participants have an expectation that everyone in the market will play by the same set of rules, states pursuing policy objectives don’t necessarily feel bound by those rules. In addition, the states have not been able, individually or collectively, to identify exactly what they want in a way that an RTO can create a market for it, he said.

Peter Fuller | © RTO Insider

Rather, states want to maintain control of resource decisions as policy objectives continue to evolve over time. “As much as anything they want to control that,” Fuller said. “If I’m a governor or legislator thinking how I want to transform the energy system in my state, my first instinct is not to send somebody to [the New England Power Pool] or to PJM to offer proposals, to come up with a matrix or a set of market rules and see how that plays out.” States are more likely to take direct action that then can cause dislocations in the markets.

Day Pitney attorney Sebastian Lombardi, who serves as counsel to NEPOOL, said that overlaying all the fuel security and grid resilience efforts is the need for regions to continue to engage in efforts to help bridge the divide between evolving state and federal policies and the market.

Sebastian Lombardi | © RTO Insider

“From a state policy perspective, the competitive markets are not always achieving what they’d like the markets to achieve,” Lombardi said.

Darlene Phillips, senior director for strategic policy and external affairs at PJM, explained the RTO’s proposed revamp of its capacity market.

The Extended Resource Carve-out proposal would allow specific, state-subsidized resources to opt out of the capacity market and PJM to adjust market clearing prices as if the resources were still in it. (See related story, PJM Stakeholders Hold Their Lines in Capacity Battle.)

Darlene Phillips | © RTO Insider

“If you don’t want your subsidized resources to get a minimum offer for price and go into the market, we will allow you to take those resources out of the market,” she said. “One of the things that FERC did not like about our original approach is that we actually paid those resources a payment.”

When it comes to existing renewable resources, PJM’s minimum offer price rule would have very little impact because the price would be zero, she said. The RTO applies a 20-MW threshold to renewables for the MOPR, which most of them don’t meet, though that situation might change with large-scale offshore wind coming along.

NERC to Try Again on Inverter Rules

By Rich Heidorn Jr.

ATLANTA — NERC stakeholders are expected to consider a new standard authorization request (SAR) to address inverter-based resources after the Standards Committee rejected two SARs proposed by CAISO in September, officials said last week.

CAISO submitted the SARs in May, saying it had recorded at least 14 occasions since August 2016 when inverter-based solar generation incorrectly tripped or ceased to operate during the routine high-speed clearing of short circuits on bulk electric system (BES) transmission. NERC has issued several reports and alerts following the two most serious incidents: the August 2016 Blue Cut wildfire, when 1,200 MW of solar disconnected; and the October 2017 Canyon 2 fire, which resulted in the loss of more than 900 MW. (See NERC Chief: Inverter, Fuel Assurance Standards Needed.)

Most solar PV generation (top map) is below the 75-MW threshold requiring registration with NERC (bottom map). | NERC

The ISO proposed incorporating performance requirements for inverter-based resources connected to the BES in a revised NERC standard PRC-024, or developing a new standard for such resources and clarifying that PRC-024 applies only to synchronous generation.

At its Sept. 13 meeting, however, the Standards Committee rejected both SARs by a 12-5 vote on a motion by Dominion Energy’s Sean Bodkin, who noted the Institute of Electrical and Electronics Engineers (IEEE) is addressing the issues in Standard 1547-2018.

James Merlo, NERC | © RTO Insider

NERC is working with IEEE on the standards for inverter settings and developing instructions on compliance monitoring and enforcement activities related to the issue, James Merlo, NERC vice president of reliability risk management, told the Member Representatives Committee (MRC) at its quarterly meeting Nov. 6.

FERC Commissioner Cheryl LaFleur, who attended the MRC and Board of Trustees meetings, said she was concerned about the rejection of the SARs, saying “nothing clarifies the mind like an enforceable standard.” She said it was better for NERC and its stakeholders to design standards rather than respond to directives from FERC.

NERC CEO Jim Robb said he was disappointed that the two SARs “met with such headwinds at the Standards Committee.”

“I think we need to get over the notion that any standard creates peril and get to the point where standards create certainty,” he said. “And I think, particularly, in the case of these inverter resources, that’s a very, very important thing for us to do. … These resources are not going away. They’re already at scale in the West, and they will [soon] be at scale … in many parts of the country.”

Merlo said the Operating and Planning committees and the Inverter-Based Resource Performance Task Force will seek a new SAR to modify PRC-024 that will build on a white paper to be released in about two weeks identifying gaps between current standards and what’s needed by grid operators. “The expectation is the Standards Committee would take that up in December,” Merlo said.

“I’m optimistic that that will accomplish much of what we wanted to accomplish through the original two SARs,” Robb said.

Howard Gugel, NERC | © RTO Insider

The work may not stop with revisions to PRC-024, said Howard Gugel, NERC senior director of engineering and standards. “Then that task force is also going to go forward to say, ‘given that this is a brave new world and we have these resources, is there another standard that we should write that says how they should actually operate?’” he said in an interview. “And it’s not just limited to solar. … [idle EVs injecting energy into the grid are] an inverter resource also.”

NERC has already asked solar generators to modify their inverter settings to ensure voltage excursions don’t result in momentary cessation (MC) — when they stop injecting current into the grid. For inverters that cannot use another ride-through mode, NERC asked that MC settings be reduced to the lowest voltage value possible and that the recovery delay be reduced to one to three electrical cycles.

In arguing for the SARs, CAISO’s Keith E. Casey, vice president of market and infrastructure development, noted that NERC guidelines are not enforceable.

“Due to a lack of any standard addressing the minimum performance of inverter-based generation connected to the BES, original equipment manufacturers often apply standards for resources connected to the distribution system to BES resources,” Casey wrote.

NERC reported that most of the lost solar generation in the Blue Cut fire resulted when inverters incorrectly perceived a low frequency condition and tripped, not returning to service for five minutes or longer. “Five minutes may make sense on a rooftop, but five minutes is an eternity on the bulk electric system,” Merlo said.

NERC, which originally surveyed 13,543 MW of solar PV as potentially using momentary cessation, now believes all but about 1,952 MW do not use it or can overcome it with modified settings. (The survey covered only utility-scale solar generators at or above 75 MW, the threshold for generators that must register with NERC.)

“We understand a lot more than we did when we first saw the event just 18 months” ago, Merlo said.

MISO Quick Capacity Reserves Wait Until 2021

By Amanda Durish Cook

MISO is working to create market rules for capacity reserves that can be supplied within 30 minutes, though the RTO won’t have a sophisticated enough technology platform to support the new product for more than two years.

RTO staff told the Market Subcommittee on Nov. 8 that the earliest the new product could be rolled out is the first half of 2021 because it will require the new market platform.

MISO Director of Market Design Kevin Vannoy said the short-term reserve product will address issues that are “more severe” than can be solved by either the ramp product and regulation reserve, which is supplied within seconds, or issues that are “less severe” than the Disturbance Control Standard events requiring the RTO’s 10-minute contingency reserves.

“The idea is to get the 30-minute reserves reflecting actual needs [of the system] rather than trying to have the 10-minute reserves covering it,” Vannoy said.

Bill Peters | © RTO Insider

“We have needs that we make out-of-market commitments for, but they’re not modeled in the market,” said Bill Peters of MISO’s market design team.

The short-term reserves would be furnished by either online generators dispatched according to opportunity costs or offline generators, which would be dispatched based on an offer price.

Peters said short-term reserves would help manage flows on SPP transmission between MISO Midwest and MISO South and aid areas hemmed in by transmission constraints or short on nimble reserves. They also will help meet load and avoid volatility as the RTO adds more intermittent resources.

MISO’s final ranking of Market Roadmap improvements placed the creation of short-term reserves at the highest priority, beating out projects to better model combined cycle generators, and respond to shifting resource availability and need.

Peters said the reserves could have market-wide, regional and local response requirements. He said MISO would dynamically schedule the reserves to a load pocket or region, assessing the state of the system, capacity needs, amount of cleared energy and amount of cleared short-term reserves before dispatch. He also said the RTO is considering applying a demand curve to pricing. Peters said the generators that sign up to provide the service will be tested to demonstrate they’re able to provide capacity within 30 minutes.

MISO has scheduled a Jan. 15 workshop to further discuss the conceptual design of a short-term reserve product.