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December 26, 2024

Canada, New England Talk Trade, Politics and Clean Energy

By Michael Kuser

BOSTON — Energy made up $130 billion of the $750 billion that changed hands last year between Canada and the U.S., the largest bilateral trading relationship in the world. Industry participants on both sides of the border question why the Trump administration would risk that relationship with protectionist tariffs.

New England-Canada Business Council
The New England-Canada Business Council (NECBC) 26th Annual Energy Trade & Technology Conference took place Nov. 1-2 in Boston. | © RTO Insider

Sergio Marchi | © RTO Insider

“We believe in building bridges, not walls,” said Canadian Electricity Association head Sergio Marchi, speaking at the New England-Canada Business Council’s (NECBC) 26th annual energy conference Thursday, where attendees also discussed the changing resource mix, investment prospects and siting challenges.

Canadians were disappointed that the energy chapter in the original North American Free Trade Agreement was not preserved in the proposed United States-Mexico-Canada Agreement, and surprised the updated energy provisions were bilateral, not trilateral, Marchi said.

“The provisions of energy in the new NAFTA are scattered across a multiplicity of different sections, and so we’re puzzled as to why you would not want to consolidate all of these provisions in one coherent place,” he said.

David Alward | © RTO Insider

David Alward, consul general of Canada to New England and a former premier of New Brunswick, said Canada did not believe the premise of the original NAFTA was unfavorable to the U.S. and noted that negotiations over the new agreement led to a pessimistic cloud of uncertainty.

“But we achieved a good agreement and brought a certain level of predictability to the relationship,” Alward said.

Paul Hibbard | © RTO Insider

The Analysis Group’s Paul Hibbard, former chairman of the Massachusetts Department of Public Utilities, said, “It’s difficult to overstate the importance of Canada in meeting energy needs and renewables. … Looking forward, the potential growth in cross-border energy trade is staggering.”

Renewable, with Gas and a Little Oil

Massachusetts Energy and Environmental Affairs Secretary Matthew Beaton said his state is “continuing to make sure that we take a combo platter approach” to include all technologies in achieving a renewable energy future.

Matthew Beaton | © RTO Insider

“The existing markets are becoming more aligned on natural gas, which will continue to play a very important role in the market price of energy here in New England,” Beaton said.

Carol Grant | © RTO Insider

Carol Grant, commissioner of the Rhode Island Office of Energy Resources, said she is optimistic that people want to contribute to a cleaner world, “but I don’t think New England or anyone is saying at any price.”

ISO-NE Vice President of Market Operations Robert Ethier said the two most important issues for the RTO are winter fuel security and “addressing the states’ desire to bring in more carbon-free resources.”

Integrating those new resources is not now a problem for the RTO and likely won’t be for the next decade, Ethier said. It’s a two-fold economic challenge involving the energy and capacity markets.

“One is, bring in these zero-marginal-cost resources and insert them into our real-time supply stack, and it lowers energy prices for everyone,” Ethier said.

Robert Ethier | © RTO Insider

Second, “when the states contract for these resources, they don’t just affect the energy market, they also affect our capacity market,” Ethier said. So the RTO developed Competitive Auctions with Sponsored Policy Resources “to insulate the capacity market outcomes from having these resources, which are by most estimates uneconomic to enter into our capacity market, but enter anyway because they have long-term state contracts.”

Having new state-sponsored resources buy out old resources in the market will help manage and ration the entry of these resources into the market and prevent price suppression, he said.

“If we want to have long-term competitive markets in New England, and we want to have the prospect of merchant investment five, 10 or 15 years from now … they need to have confidence that there are going to be market opportunities for them into the future that make it worth their while to invest their money,” Ethier said.

Dan Dolan, president of the New England Power Generators Association, said 60% of the region’s electricity will soon come from state-sponsored resources not dependent on the wholesale market, “but the market is not structured to protect the 40% of generators who will remain dependent on the market.”

One of the panels at NECBC (left to right): Robert Ethier, ISO-NE; Dena Wiggins, NGSA; Paul Hubbard, Analysis Group; Sergio Marchi, CEA; and Seth Jaffe, Foley Hoag. | © RTO Insider

On fuel security, Ethier said the market needs to incent gas-burning generators to fully utilize LNG facilities and also ensure the region continues to maintain its existing fleet of oil-burning resources, at least in the near term.

“Those resources have remarkably low capacity factors for resources that were built as baseload … in the 1 to 2% range, so they hardly ever run,” Ethier said. “The thing is, when they do run, we really need them.”

Dena Wiggins | © RTO Insider

Dena Wiggins, president of the Natural Gas Supply Association, said that ample and diverse natural gas supplies balance the current weak U.S. gas storage picture of about 3 Tcf, so that a disruption to production in one place no longer spikes prices.

“It’s a little bit different here in New England, but those are spot prices,” Wiggins said in reference to potential spikes. “Our consultant tells us that during the winter peaks, only about 1% of the gas traded at those high prices.”

Siting Concerns

John Gulliver | © RTO Insider

Attorney John Gulliver of Pierce Atwood compared 2000 with 2017, with New England nuclear remaining steady over that period, producing 31% of power, while oil moved from 22% to 0.7%, coal declined from 18% to 2% and natural gas grew from 15% to 48% — “with the balance made up by healthy growth in hydro and renewables.”

Seth Jaffe | © RTO Insider

Attorney Seth Jaffe of Foley Hoag said policymakers may be willing to pay the price for pursuing their political goals of a carbon-free economy, but both gas pipelines and hydropower transmission from Canada have had problems getting sited, even when hydro nominally supplants the need to burn natural gas. “You have to wonder, how are we going to get these projects done?”

Avangrid CEO James P. Torgerson said the difficulty in siting onshore wind in New York and New England is just one reason why offshore is more appealing.

James P. Torgerson | © RTO Insider

“You still have to deal with the intermittency, but the good thing about offshore wind [is] the capacity factors we’re seeing for that should be in the 50% range,” compared with 33% for existing onshore wind and 40% for new onshore projects, Torgerson said.

Speaking about Avangrid’s New England Clean Energy Connect (NECEC), a project of subsidiary Central Maine Power to bring 1,200 MW of Canadian hydropower to Massachusetts, Torgerson said, “We expect to get all the approvals in 2019,” despite Maine regulators in October having suspended hearings on the project. (See Maine PUC Move Poses Hurdle for NECEC.)

The Maine Public Utilities Commission on Nov. 2 scheduled several technical conferences in the case (Docket No. 2017-00232) ahead of resuming hearings January.

“Some communities are not as supportive as they initially were … but things evolve,” Torgerson said.

NECEC faces some of the same issues as Northern Pass did in New Hampshire, so when Maine environmentalists protested plans to string high-voltage lines across the Kennebec Gorge, for example, Avangrid agreed to tunnel under the river, he said.

The project to deliver Quebec’s hydropower will reduce electricity prices in Maine by about $40 million a year, provide communities $18 million a year in tax benefits and add more than $500 million to Maine’s GDP, Torgerson said.

Ian Robertson | © RTO Insider

Algonquin Power & Utilities CEO Ian Robertson noted how the intermittency of renewables is declining and the potential for storage to assist the trend.

“We’re all trying to understand how battery storage fits into that equation. Part of what we’re doing is working with regulators to put 500 of the Tesla Powerwalls in,” Robertson said. “But I’m not sure anybody in a utility really understands how storage can be most effectively introduced into an electric grid to create value for customers.”

FERC OKs Adjusted Rate for Disputed Transource Line

By Rory D. Sweeney

FERC on Thursday approved the designated entity agreement (DEA) for Transource Energy’s Independence Energy Connection, PJM’s largest-ever congestion-reducing transmission project, with one condition: that Transource stick to its original commitment for how long it can use an increased amount of equity in its rates (ER17-349).

The commission ordered that PJM submit a compliance filing within 30 days on the project that aligns the return on equity allowed for Transource in the DEA with the amount agreed to in a settlement agreement in the case. The current DEA limits Transource’s formula rates to 50% equity “once permanent financing is in place” and as long as capital market conditions “remain normal.”

Transource Energy’s Independence Energy Connection will be PJM’s largest-ever congestion-reducing transmission project. | Transource

The settlement requires Transource to reduce its equity mix from 60% to 50% by June 1, 2020. The reduction would be triggered earlier if the project goes into service or permanent financing is obtained.

The $366.2 million 230-kV project is being opposed by some residents along its path between Washington County, Md., and Franklin County, Pa. (See PJM Redirects Residents’ Protests of Tx Project to States.)

The compliance filing is the third in the project’s approval path. The DEA was conditionally accepted on Jan. 12, 2017, and PJM submitted its compliance filing on March 2. That filing is now accepted with the required changes.

Transource’s Independence Energy Connection project consists of two separate lines that run north-south across the Pennsylvania-Maryland border. | Transource

The DEA approval was also conditional on the outcome of the project’s formula rate proceeding. The formula rate was conditionally approved on Jan. 31, 2017, and PJM submitted its compliance filing on March 2, 2017.

Transource requested rehearing of the formula rate but joined PJM in submitting a settlement offer on Oct. 2, 2017. FERC conditionally accepted the settlement on Jan. 18, 2018. PJM submitted its compliance filing on Feb. 16, which the commission approved on Sept. 21. The rehearing request was denied on July 6.

SPP Board of Directors/Member Committee Briefs: Oct. 30, 2018

By Tom Kleckner

The SPP Board of Directors and Members Committee met Oct. 30. | © RTO Insider

Stakeholders Honor Eckelberger, Skilton’s Service

LITTLE ROCK, Ark. — SPP directors, members, staff and other stakeholders took time out last week from the normal board week activities to honor two directors who predate the organization’s RTO status.

The RTO treated Jim Eckelberger, who stepped down in April after 14 years as the Board of Directors’ chairman, and Harry Skilton, vice chair for 14 years, to a catered farm-to-table dinner the night before the Oct. 30 board meeting.

The SPP board and members give Skilton (foreground) and Eckelberger a standing ovation. | © RTO Insider

Staff shared a video of family, friends and stakeholders sharing their favorite anecdotes about the two men. Both were presented with plaques topped by — what else? — replicas of transmission towers.

Eckelberger and Skilton are the last remaining members of SPP’s original board, which was created in 2000. FERC didn’t recognize SPP as an RTO until 2004.

Since then, SPP has expanded its footprint with the addition of Nebraska utilities and the Integrated System, and by offering reliability coordination (RC) services to Western Interconnection entities. The RTO has also become one of the lowest-cost grid operators by creating day-ahead and financial transmission rights markets and investing billions in transmission infrastructure.

Eckelberger, who takes great pride in SPP’s cost of service, pointed to an LMP contour map of the footprint, dominated by the cool blue denoting prices in the $20 to 30/MWh range, as an example of the RTO’s effectiveness.

“SPP greatly appreciates the 18 years Jim and Harry dedicated to SPP,” CEO Nick Brown said. “They have made extraordinary contributions to our company and were instrumental in transforming SPP into the regional transmission organization we are today.”

“Both should be proud of the legacy they have created here for SPP,” said Larry Altenbaumer, who replaced Eckelberger as chairman in April.

“I’m very fortunate to have 18 years at SPP be the capstone of my career,” Skilton said.

Both men are transitioning into emeritus status, effective Jan. 1.

“We’re fortunate they’ll be staying on in this emeritus role, because they have a wealth of experience,” said the Members Committee’s Tom Kent, COO for Nebraska Public Power District.

Awards of recognition for Skilton and Eckelberger | © RTO Insider

Members Elect 2 New Directors

The Members Committee replaced Eckelberger and Skilton on the board by electing newcomers Susan Certoma and Darcy Ortiz during its annual meeting. The appointments are effective Jan. 1.

Bruce Scherr, who joined the board in January 2016, was also re-elected.

Newly elected Director Susan Certoma | © RTO Insider

Certoma is president of Enterprise Engineering, which provides software and consulting to financial firms. She previously held technology-related positions at Wachovia Bank, Goldman Sachs, Merrill Lynch and Lehman Brothers during 30 years in the finance field. Certoma holds a bachelor’s degree in management and economics and an MBA from St. John’s University.

Ortiz is Intel’s vice president and general manager of corporate services. She previously led the global team responsible for Intel’s IT operations and services and served in several CIO positions. She has a bachelor’s degree in business administration from the University of New Mexico and an MBA from the University of California, Berkeley.

Brown said the new members’ technology backgrounds will be invaluable to SPP.

“Much of our continued success now hinges on effective management of data and technology infrastructure and our approach to cybersecurity,” he said in a statement.

The committee also elected seven representatives to three-year terms on the committee, with “the narrowest of unanimous margins,” Altenbaumer joked.

Members Committee ballot | © RTO Insider

The representatives are Kent for State Power Agencies; Blake Mertens (Empire District) and Kevin Noblet (Evergy) for Investor-Owned Utilities; Jason Atwood (Northeast Texas Electric Cooperative) and Mike Wise (Golden Spread Electric Cooperative) for Cooperatives; Kevin Smith (Tenaska Power Services) for Independent Power Producers/Marketers; and Jody Sundsted (Western Area Power Administration – Upper Great Plains) for Federal Power Marketing Agencies.

Mertens is the only newcomer; everyone else was re-elected.

Altenbaumer Tweaks New Governance Schedule

Altenbaumer continues to tinker with the board’s meeting schedule as he enters his first full year as chairman, saying he wants to “elevate the work of the board and members to focus on those things that are strategically important.” (See SPP Strategic Planning Committee Briefs: Oct. 18, 2018.)

Board Chair Larry Altenbaumer explains changes in 2019 as CEO Nick Brown (left) and Director Graham Edwards listen. | © RTO Insider

Following feedback from members and the Regional State Committee, Altenbaumer has scheduled a joint session between the board and RSC on the day the state regulators normally meet (the day before the board’s quarterly meeting). That time will be used for joint informational and background presentations to the directors, members and RSC.

“It’s an opportunity to become more efficient,” Altenbaumer said. “Many presentations given to the RSC turn out to be warmups for the same presentations to the board the next day.”

Altenbaumer has left slots in the RSC and board meetings for executive sessions, but he promised “anything that relates to decisions will be addressed during the typical [open] board meeting.”

Addressing stakeholder concerns that the changes could reduce transparency, Altenbaumer said keeping discussions from public view is “by far the last thing intended from this.”

“If any of you ever feel these things are trending in the wrong direction, as far as engagement and transparency, bring it to my attention,” he said.

Given a chance to respond publicly to Altenbaumer’s comments, no one did.

As proof of how governance will be handled in the future, Altenbaumer noted the board’s only approval item was the consent agenda.

“That speaks to the collaborative process,” he said. “This is a desire to try and improve the overall governance.”

Two days later, SPP moved its December board meeting, which has traditionally been used to approve the budget, from Little Rock to the more accessible Dallas/Fort Worth International Airport. The meeting has also been shortened by two hours; next year, it will likely become a conference call.

MMU Clarifies its Role in Generator Retirements

MMU Executive Director Keith Collins addresses the board and members. | © RTO Insider

Keith Collins, executive director of SPP’s Market Monitoring Unit, clarified comments he made during recent governance meetings that raised stakeholder concerns about the MMU’s involvement in generator retirement decisions. (See Stakeholders Push Back Against SPP Retirement Changes.)

At October’s Markets and Operations Policy Committee and Strategic Planning Committee meetings, some stakeholders pushed back against the possibility of the MMU intervening in regulatory proceedings. Collins said the MMU would only raise concerns in instances of physical withholding or other market power issues.

“The SPP Tariff is very clear,” he said. “Physical withholding and market power are under the MMU’s purview.”

“The MMU has an obligation to investigate and review those issues,” said Director Joshua W. Martin III, who chairs the Oversight Committee. The MMU reports to Martin’s committee.

Collins said the MMU has always used available data when it reviews generator retirement requests, and that the MOPC discussion was an attempt to collect data from market participants to improve its analysis.

He noted the Tariff is unclear as what the MMU should do if it identifies physical withholding or market power.

“Our responsibility rests with FERC,” Collins said. “To the extent we identify market power of physical withholding, we would have to raise that issue with FERC, unless the protocols or the Tariff [are] clarified as to what steps should be taken.”

“The Oversight Committee has reviewed this issue, and we’re comfortable with where it is right now,” Martin said.

SPP staff have said they will provide the MOPC and the board draft Tariff revisions for generator retirement procedures in January.

SPP-MISO Operating Procedures not yet Documented

Brown said during his president’s report that it is “untenable” that SPP and MISO “end up in situations where our operators are confused,” as happened in January’s “Big Chill” event.

The two RTOs have increased their coordination across their seam since the Jan. 17 event, when severe cold weather and generation shortfalls in MISO South led MISO to exceed its regional dispatch limit on transfers between its northern and southern footprints across SPP’s system. MISO made emergency energy purchases from Southern Co. before operations returned to normal.

Brown recalled that shortly after the event, he had told the board that one of his top priorities for the year was to reach an agreement with MISO on “exact operating procedures.”

“I was hoping to report we have signed documents for this meeting, but we don’t,” Brown said.

He was able to share with directors and members a pamphlet that says SPP members receive $1.7 billion in annual benefits, an 11-1 benefit-cost ratio. The document notes the Integrated Marketplace has produced more than $2 billion in savings since going online in 2014 and references a study that indicates every dollar SPP spends on transmission investment returns $3.50 in benefits.

“I would have no problem standing before any regulatory committee and defending these numbers,” Brown said.

Western RC Services to Net $3.4M

Operations Vice President Bruce Rew said SPP’s RC contracts with Western Interconnection entities will result in $3.4 million in net income through 2024. (See CAISO RC Wins Most of the West.)

SPP expects to earn $28.4 million in revenue over the life of the five-year contracts, which are effective in January 2020. However, adding up to 20 staffers in Little Rock to handle the new responsibilities will eat into much of that revenue.

Under the contract’s terms, the Western entities will pay an initial 5.5 cents/MWh. Annual extensions will begin in 2025, and mutual withdrawal provisions are included.

Smaller entities may yet participate in SPP’s RC services, Rew said. Later entities would be evaluated on a case-by-case basis.

Consent Agenda’s Approval Adds, Deletes Members

The board’s consent agenda included changes to the membership agreement that would clear the way for Mor-Gran-Sou Electric Cooperative to become the newest SPP member.

The Corporate Governance Committee approved membership agreement amendments for the North Dakota co-op similar to changes that facilitated the membership of Basin Electric Power Cooperative and its members as part of the Integrated System’s integration. Mor-Gran-Sou, which is embedded within the Integrated System, intends to join SPP as a transmission owner.

The CGC also recommended Cielo Wind Power’s membership be terminated immediately for failing to keep up with its membership dues and repayment agreements. SPP said Cielo in January stopped responding to the RTO’s outreach efforts and ignored a March demand letter.

The Austin, Texas-based company’s delinquency dates back to 2016. It owes $18,000 and interest.

The consent agenda also included staff’s recommendation to revise the SPP-MISO Coordinated System Plan. (See “MOPC Approves Changes to Joint Model with MISO,” SPP MOPC Briefs: Oct. 16-17, 2018). Also on the agenda were the Finance Committee’s 2019 operating plan, updates to the 2019 Integrated Transmission Planning assessment’s scope, the Market Working Group’s annual violation relaxation limits analysis, and nine revision requests:

  • MWG RR266: Substitutes “interest” for “ownership” in language modeling joint-owned units as single resources, recognizing that “ownership” doesn’t capture stakeholder intent that power purchase agreements and other non-ownership interests be included.
  • MWG RR288: Allows non-dispatchable variable energy resources converting to dispatchable status to use control statuses not originally available to them. SPP’s control statuses are: offline (the resource is not operating); non-regulating (online and capable of following a dispatch instruction or contingency reserve deployment but not eligible to clear regulation service); regulating (online and capable of following dispatch or contingency reserve instruction, and regulation deployment); and manual (online but not able to follow dispatch; e.g., start-up, shutdown, testing, etc.).
  • MWG RR316: Updates the multi-configuration (combined cycle) resource market design by adding two additional commitment parameters: group minimum down time and plant minimum down time. Also removes sync-to-min and min-to-off times from the submitted minimum down time or group minimum down time when the resource transitions between operational configurations. The current design only allows individual registered configurations to submit a minimum down time.
  • MWG RR323: Defines batteries as electric storage resources (ESRs), capable of being dispatched and participating in price formation. Excluded as ESRs are those resources that are either contractually barred or physically incapable of injecting energy back onto the grid because of their design or configuration. Also creates a new registration type, “market storage resource,” to be used only by ESRs.
  • MWG RR332: Corrects protocol calculations from designs implemented in RR200 (design change for bilateral settlement schedules (BSS) and over-collected losses (OCL) distribution) and RR235 (correction to RR200) necessary to accurately distribute OCLs and ensure BSS are receiving their correct OCL. The change ensures corrected resettlements back to the original May 1, 2018, release date.
  • ORWG RR318: Changes the contingency reserve requirement calculation to allow the use of the “most severe single contingency” as the basis of the minimum contingency reserve requirement on an hourly basis. SPP said the revision allows it to more accurately and reliably set the reserve requirement.
  • RTWG RR305: Updates Tariff language following modifications to the aggregate facilities study process by removing the requirement to file a service agreement before modeling new transmission service in the ITP models. Also removes the requirement that SPP issue notifications to construct (NTC) and notifications to construct with conditions (NTC-C) before filing a service agreement. Adds a financial commitment date of four years to the issuance of an NTC or NTC-C.
  • RTWG RR322: Changes the Tariff and other documents to reflect that the RTO is no longer using U.S. Energy Information Administration data in monthly load forecasts. SPP said the data in the EIA report are not granular enough because they are at the balancing authority level, rather than the local balancing authority level required. In January, the RTO began using forecast data that are available through the NERC system data exchange (SDX) and historical data where forecasts are not available.
  • RTWG RR325: Revises SPP’s pro forma language for large generator interconnection procedures and large generator interconnection agreements to comply with FERC Order 845.

Microgrids Seek Path out of Regulatory Limbo

By Michael Brooks

BALTIMORE — The drafters of the 1935 Federal Power Act could not have imagined modern distributed energy resources, let alone a small network of them that can operate independently of the grid.

FERC
FERC Commissioner Cheryl LaFleur addresses the Microgrid 2.0 conference in Baltimore. | International District Energy Association

“The phenomenon that I think FERC confronts and other agencies in Washington confront is that there’s been a lot more technological change than there’s been legislative change for a whole bunch of reasons that are above my pay grade to diagnose,” Commissioner Cheryl LaFleur told attendees of Microgrid 2.0 at the Hyatt Regency Baltimore Inner Harbor last week.

FERC Commissioner Cheryl LaFleur | International District Energy Association

“We’re trying to solve 21st century problems using … a 1930s law.”

How microgrids should be regulated was a central topic at the third annual conference held by the International District Energy Association (IDEA), which advocates for distributed generation, district heating and cooling, and combined heat and power.

Christopher Berendt, Drinker Biddle & Reath | International District Energy Association

“The reason we’re here talking about this today, probably more than anything else, is that consumer demand is driving us, and that we’re seeing more and more people say, ‘We want to see mixed-use, multi-customer microgrids because we want the variety of benefits that can come out of them,’” Christopher Berendt, counsel to IDEA’s Microgrid Resources Coalition, said during a panel on market design and policies.

Regulatory risk, he said, “acts kind of like repellant to private capital.”

“There is more capital waiting to flow into microgrid investment right now [that] you would not believe,” said Berendt, a partner with Drinker Biddle & Reath. “There is more capital chasing fewer good projects, and what is really needed to unlock those loads of capital and get more good steel in the ground is not the desire to deploy it, but the regulatory frameworks that support project financing.”

Without any direction from Congress, however, regulators must work with what they have. During her luncheon keynote speech, LaFleur pointed to the complications of DER aggregation, which the commission has been working on for nearly two years. (See FERC Rule Would Boost Energy Storage, DER.)

“It seems quite clear that distributed resources can be aggregated and bid into the market and contribute great value. But since they’re, in many cases, behind the meter, what do the states figure out? Who gets the first bite of the value?” LaFleur asked. “How are we going to figure out who pays what to whom in a sensible way? I think our staff has made a lot of progress in thinking about it. I think it can be worked through, but it’s a little more complicated than some of the … issues we usually deal with because of the number of different uses, and because although it acts wholesale when we see it in the markets, it’s actually at the distribution level.”

Commissioner Richard Glick told the Energy Bar Association last week he hopes the commission will act soon to encourage aggregation of DERs in wholesale markets. (See related story, Nearing 1-Year Mark, Glick Rejects ‘National Security’ Grid Risk.)

Dan Dobbs, Anbaric Development Partners | International District Energy Association

The industry also faces challenges at the state and local levels over siting rights of way and whether microgrids are defined as public utilities. “One thing all jurisdictions in this country have in common is that they’re not set up for microgrids,” Berendt said

Dan Dobbs, vice president of distributed energy for Anbaric Development Partners, pointed to New York’s Value of Distributed Energy Resources tariff as “a start.” (See NYPSC Takes Subway into Value Stack.)

“It’s not perfect, but it’s a good attempt at getting that value,” he said. But “you really need to be able to value power that comes in and goes out equally. That’s at the retail level, and you need to be able to do that similarly at the wholesale level when you are aggregating resources.”

FERC Sets GridLiance’s Zonal Placement for Hearing

By Tom Kleckner

FERC last week allowed GridLiance High Plains to begin rate recovery Nov. 1 for its facilities in the Oklahoma Panhandle but set the company’s proposed annual transmission revenue requirement subject to refund and settlement judge procedures (ER18-2358).

The Oct. 31 order rejected requests from SPP transmission owners to reject the filing or suspend rate recovery.

GridLiance’s assets, 410 miles of 69- and 115-kV lines and related substation infrastructure, were acquired in 2016 from Tri-County Elec. Co-op. (See GridLiance Closes Deal for Tri-County Co-Op’s Tx Assets.)

SPP placed the facilities in Southwestern Public Service’s transmission pricing zone, Zone 11. The RTO said in its August filing that GridLiance’s ATRR and facilities were not large enough to warrant their own pricing zone, and that they were also interconnected solely with Zone 11 facilities.

Tri-County service territory | Tri-County Elec. Co-op

It said the addition of the GridLiance assets will increase Zone 11’s ATRR of $112 million by 6.9%. Network integration transmission service charges will rise 2.8% if the ATRR of transmission facilities whose costs are recovered under Schedule 11 (Wholesale Distribution Service) is included, the RTO said.

More than a dozen SPP TOs and cooperatives and the Texas Public Utility Commission protested SPP’s filing, arguing that the RTO did not explain how upgrades GridLiance made to the Tri-County assets benefit existing Zone 11 customers and questioning how FERC could determine the additional costs were fair without analyzing the benefits.

Xcel Energy complained that GridLiance constructed more than $50 million of facilities outside the SPP regional transmission planning process even though the Tri-County load has decreased by at least 23 MW since 2016.

GridLiance said its planned and constructed upgrades address outages from ice and wind storms that resulted from a non-networked system.

Brett Hooton, president of GridLiance High Plains, said he was pleased FERC denied requests to reject the filing or suspend rate recovery.

“We look forward to demonstrating why wholesale loads are entitled to enjoy comparable reliability as the load served by the dominate transmission owners within SPP and how our reliability improvement upgrades meet that goal,” he told RTO Insider.

Commission OKs Revised ‘Financial Interest’ Definition

The commission also accepted revisions to SPP’s bylaws that clarify the concept of a financial interest. With the Nov. 1 order, SPP employees, directors and their spouses, minor children, and any person for whom they have power of attorney or guardianship rights will be allowed to invest in companies that have a de minimis relationship with the RTO and the electric sector (ER18-2376).

FERC agreed that SPP’s rules, developed before the expansion of its membership and market participation, created barriers in recruiting and retaining directors and employees. The commission said the bylaw revisions should continue “to safeguard SPP’s independence” by prohibiting directors and employees from investing in market participants active in the Integrated Marketplace.

FERC Order 2000 bars grid operators, staff and non-stakeholder directors from holding financial interests in any market participant and require them to maintain independence from “any entity whose economic or commercial interests could be significantly affected by the RTO’s actions or decisions.”

FERC OKs MISO External Capacity Zones, Dispute Deadlines

By Amanda Durish Cook

MISO can create external zones for its annual capacity auction and place time limits on members’ settlement disputes, FERC ruled in a pair of Oct. 31 orders.

The first order allows MISO to create external resource zones and modify capacity import and export limits to align with them. Excess auction revenues will be divided among load-serving entities with historic supply arrangements that may be affected by the new zones (ER18-2363).

MISO external zones | MISO

FERC said distinguishing external capacity suppliers from internal ones would preserve the intent of the RTO’s local clearing requirement. “We find it just and reasonable … for MISO to no longer count all external resources, regardless of electrical distance and dispatch control, towards satisfying the local clearing requirements for MISO’s local zones. Continuing to do so would undermine the purpose of the local clearing requirement, which is to ensure that a sufficient amount of unforced capacity is located within each local zone so that each local zone can meet its [loss-of-load expectation] during its local zone peak demand when it is import-constrained,” the commission said.

FERC also brushed aside stakeholder protests that the RTO’s plan was hasty because its current treatment of external resources was not causing reliability issues. “A transmission operator need not wait until there is a reliability event before proposing tariff revisions to prevent one,” the commission said.

It also rebutted municipal agencies’ argument that WPPI Energy’s Nelson Energy Center in Illinois should be considered a border external resource because Exelon’s Quad Cities nuclear plant is considered one. The commission said that while Quad Cities is directly connected to the MISO system, the Nelson plant “requires intervening transmission to reach the MISO transmission system” and doesn’t follow a predictable path. FERC also declined to speculate on municipal agencies’ concerns over how the RTO might treat future external generation using the proposed Grain Belt Express HVDC line, saying such discussion was “premature.”

Nelson Energy Center | MJ Electric

FERC had rejected MISO’s plan for external capacity zones in August, taking issue with a proposal allowing an external resource bordering more than one local resource zone to choose which zone to participate in during the auction. The commission also rejected a provision that would have allowed holders of evergreen supply contracts written prior to the RTO’s capacity construct to receive historical supply arrangement credits in perpetuity.

MISO responded with edits that made evergreen contract extensions eligible for excess auction revenues for the original term of the contract or two years, whichever is longer, and a new electrical connectivity analysis that ensures external resources bordering more than one local resource zone participate in only one zone. (See MISO Adds Study to 2nd External Zone Filing.)

FERC accepted both changes and said the two-year limit would ensure that resources won’t be able to “permanently avoid the locational price signal that MISO’s resource adequacy construct was designed to provide.” But the commission said that the RTO should notify owners of external resources bordering multiple zones which zone they’ll be assigned to in the upcoming auction. MISO agreed to provide the notice.

Limits on Settlement Dispute Resolution

FERC’s other order allows MISO to bar settlement disputes that are not initiated within approximately four months (ER18-1648-001).

Effective Nov. 1, members have a 120-day time limit for initiating transmission or market settlement disputes and another 90 days to request either an informal or formal alternative dispute resolution if the member doesn’t like MISO’s response. The RTO has two years from the operating day in question to make resettlement corrections. Resettlement outside the two-year cutoff would require MISO and the participant to seek a Tariff waiver with FERC. The commission’s order permits MISO to create a “Limitations on Claims and Adjustments” section of its Tariff.

The 120 days will be counted from the operating day of the market settlement in question or the date of the first transmission settlement invoice. The 90 days are counted from the day the settlement dispute was “resolved or determined” by MISO.

The RTO said the two years would also apply to settlement errors that it “unilaterally discovers without a related dispute submission by a market participant.”

Until now, MISO’s Tariff did not prohibit settlement disputes that are not submitted within specified time periods.

MISO’s first attempt at the dispute resolution filing was met with a FERC deficiency letter, questioning the two-year requirement. (See FERC Seeks Details on MISO Dispute Resolution Plan.) The RTO argued “that the need for market certainty and promptness of claims supports a two-year resettlement period.” It added the definition of “continuing error” to the two-year provision, which covers “continuing, system, software or other execution that is inconsistent with the Tariff.” The term replaces the undefined terms “system error” and “software error,” which MISO used in its first filing.

MISO said it only foresees two kinds of transmission and market settlement errors: those in system procedures or software that take longer to identify or “execution errors,” including human errors, that are more easily identifiable.

FERC said the RTO’s proposal strikes an “appropriate balance between requiring market participants to promptly initiate claims involving readily discoverable one-time MISO errors and the correction of more long-lasting MISO errors that may not be readily discoverable.”

MISO Pivots to Near-term Resource Availability Fixes

By Amanda Durish Cook

CARMEL, Ind. — MISO has mostly focused its multiyear resource availability and need initiative on big-picture solutions, but RTO staff now say they will zero in on three short-term fixes that can be rolled out early next year.

The shift comes after stakeholders expressed the need for near-term improvements in MISO’s effort to address the growing mismatch between its changing resource availability and demand. (See MISO Narrowing Options on Resource Availability Fix.)

MISO’s Nov. 1 Reliability Subcommittee gets underway. | © RTO Insider

“We agree and we’d like to take some near-term action to give us the space to work on holistic solutions,” MISO Executive Director of Market Development Jeff Bladen said during a Nov. 1 Reliability Subcommittee meeting. “We do need the operational breathing room to work on those long-term solutions.”

MISO will likely make a FERC filing for short-term solutions before the end of the year while spending “the bulk” of 2019 on longer-term improvements, Bladen said. MISO’s near-term objective is to make 5 to 10 GW of additional supply more available by the spring, focusing on stricter load-modifying resource (LMR) obligations, more advanced notice of planned outages to members and firmer planned outage requirements.

Jeff Bladen | © RTO Insider

“Our goal now is not to get to perfect, but get to better,” Bladen said.

MISO next year expects to focus on how resources are accredited in the annual Planning Resource Auction. Beyond that, Bladen said the RTO will work on new market incentives to spur resource availability and a possible seasonal resource adequacy construct.

Outages

MISO wants to create a region-by-region forward rolling forecast of planned outages in its North, South and Central regions “many, many months in advance,” Bladen said.

The RTO is seeking stakeholder input on the definition of a planned outage and the lead time required. The Tariff does not currently spell out a notification period for planned outages, instead leaving stakeholders to interpret the NERC standard of “well in advance.”

Bladen said MISO received suggestions to deem any outages submitted less than a month in advance as “forced.” Stakeholders have also asked the RTO to consider transitioning to a “total” outage rating for generators that includes planned outages and derates, not simply a forced outage rate.

But Bladen said MISO’s recommendation is to consider all outages and derates as forced outages only during periods of low availability of capacity reserves unless the asset owner has provided ample notice of a planned outage. The RTO has not yet determined a possible notification lead time, nor has it defined what would constitute “low reserves,” though Bladen said it may require a 120-day notice period for an outage to be considered planned and anywhere from 5 to 7% in available reserves before MISO declares low availability.

WPPI Energy’s Valy Goepfrich said the RTO could also simply increase its expected forced outage rates for generators.

Bladen said MISO currently experiences a “double camel’s hump” of planned outages in April and October, when maintenance outages spike. He said increasing outages, combined with diminishing reserves, increase the potential of firm load shedding.

Xcel Energy’s Kari Hassler said the RTO could request that generation owners smooth out the two concentrations of outages during the year.

“This is direct correlation of our aging fleet. … It’s something we have to account for in operations,” Bladen said, adding that MISO’s improved transparency around planned outages will require a “heavy lift” from member utilities. He said the RTO’s planned outage data are only as good as what generation owners provide: “If we don’t know outages are coming, we can’t” inform stakeholders.

Minnesota Public Utilities Commission staff member Hwikwon Ham pointed out that multiple generators that were in poor condition have retired in the past few years.

Bladen said that while a transition to a newer generation fleet is a possibility, MISO should work proactively with what generation it has now to ensure reliability while fleet evolution continues.

“We have to account for these trends, even in the short term. We can’t assume a younger fleet, even if the queue tells us that’s on the horizon,” Bladen said. He also noted MISO is seeing more new resources categorized as LMRs, available only in emergencies.

LMRs

MISO is also recommending calling on long-lead-time LMRs ahead of an emergency declaration rather than after. Some stakeholders have asked that LMRs meet a defined response time, perhaps two hours. Bladen said that was something for future consideration but not yet a MISO recommendation. He also said the RTO recommends requiring LMRs to participate in annual testing of their load-tempering capabilities.

Occidental Petroleum’s Suzanne Mottin said MISO’s suggestions were “concerning.” She said Occidental’s LMR service comes with a contract with its utility and guarantees a notification time. “I don’t know how you roll this out with these contracts,” she said.

Coalition of Midwest Transmission Customers attorney Jim Dauphinais pointed out that LMRs are already subject to performance penalties not applicable to other classes of MISO generation.

Bladen said MISO is seeking that and other stakeholder feedback, noting the RTO is not aiming to make LMR participation so “onerous” that most entities are unlikely to sign up.

MISO will also undertake capital spending next year to make it easier for asset owners to communicate through the LMR availability reporting platform. Stakeholders have criticized the usability of the RTO’s current setup.

Bladen also asked for stakeholder feedback on MISO’s recommendation to issue earlier instructions to LMRs in anticipation of tight operations.

“What we’re talking about is the operators being more ready to call on LMRs. They’re pretty smart, and they can see those things in advance,” Bladen said.

MISO will schedule a stakeholder workshop in late November to go over more specific proposals on LMRs and outages, Bladen said.

FERC OKs CAISO Changes to EIM Bid Adders

By Hudson Sangree

FERC last week approved CAISO’s proposal to revise its bid adder for the Western Energy Imbalance Market, allowing the changes to take effect Nov. 1.

The revisions limit the megawatt quantity of the bid adder, which reflects the costs EIM resources pay to comply with California’s greenhouse gas regulations (ER18-2341).

EIM resources sending energy to California must comply with the state Air Resources Board’s GHG regulations and pay associated compliance costs. External resources receive a payment to offset those costs when they are dispatched to serve CAISO load. (See EIM Members Seek More Details on GHG Accounting Plan.)

CAISO
Transmission lines near Blythe, Calif. | U.S. Bureau of Reclamation

The change addresses stakeholders’ concern that the market might designate a resource as supporting a transfer into CAISO even when the resource would have operated at the same level to serve load outside the ISO.

To deal with the problem, CAISO proposed limiting the hourly megawatt quantity of the bid adder to the resource’s dispatchable bid range between its base schedule and its upper economic bid for the operating hour.

“We find that CAISO’s proposal will more accurately attribute EIM transfers to the actual generation being incrementally dispatched to serve California load and will reduce the attribution to CAISO load of EIM resources that would have generated even without CAISO load, as reflected in EIM base schedules,” the commission said.

However, FERC also directed CAISO to file an informational report on the results of the changes by Jan. 1, 2020. The report is intended to provide greater market transparency and address concerns by CAISO’s Department of Market Monitoring (DMM) that the Tariff changes could undermine market efficiency. (See CAISO, ARB to Address Imbalance Market Carbon Leakage.)

“The report must describe the extent to which situations similar to the scenario described by DMM in its comments to CAISO’s stakeholder process materialize during the 12 months after the implementation of CAISO’s Tariff revisions,” the commission said.

Ratemaking Rules Pose Challenge for Tx Technology

By Rich Heidorn Jr.

Energy Bar Association
Peter Esposito, Crested Butte Catalysts, left, moderated an EBA general session discussion on regulators’ difficulty keeping up with new technologies. Also participating were, from left, former FERC Commissioner Nora Brownell; Hannah Polikov, Advanced Energy Economy; Gregg Rotenberg, Smart Wires; Susan Pope, FTI Consulting; Mark Jamison, University of Florida and Kelly Speakes-Backman, Energy Storage Association. | © RTO Insider

WASHINGTON — The role of regulators in adapting to new transmission technology was the topic for the opening general session of the Energy Bar Association’s Mid-Year Energy Forum last week, where Mark Jamison gave a history lesson.

Energy Bar Association
Mark Jamison, University of Florida | © RTO Insider

Jamison, director of the Public Utility Research Center at the University of Florida, said the telecommunications revolution that followed the breakup of AT&T’s monopoly in 1984 illustrates what he called the “myths” of industry transformations.

“One of those myths is we can … create the future by rearranging the components of the past,” he said. “What happens is when you … start opening things up to competition … the real underlying economics of the system just comes roaring out and it creates a future that we did not anticipate.”

The breakup of AT&T assumed a difference between local telephone service and long-distance service, he said. “Once we opened the markets, we found out that that assumption was fundamentally flawed. The technologies, the customers said, are not distinct from each other.”

Jamison said the electric industry is likely to be upended by technologies such as blockchain and artificial intelligence.

“It could drive us to larger, more expansive utility services, or it could shrink them down further. It all depends upon how the economics actually play out,” he said. “Blockchain would tend to disassemble things; artificial intelligence could put things back together again, make them even bigger. We just don’t know.”

Energy Bar Association
Nora Mead Brownell, National Grid | © RTO Insider

Former FERC Commissioner Nora Mead Brownell also cited blockchain and AI as technologies she is watching. She also is keen on transmission technology.

“We spend time talking about generation mix — candidly perhaps a little too much — and not enough time talking about all the [transmission and distribution] technologies that can add efficiency, add transparency, have applications that solve for multiple problems, like cyber, like customer interaction … and solve for reliability and resiliency,” said Brownell, who serves on the boards of several technology companies in addition to that of U.K.-based utility National Grid.

A Call for Short-term Thinking

Energy Bar Association
Gregg Rotenberg, Smart Wires | © RTO Insider

Gregg Rotenberg, CEO of Smart Wires, called for less emphasis on long-term transmission planning and more focus on short-term needs. “We’re getting far worse [at predicting the needs of the future grid]. This changeover in generation … is incredibly difficult to predict. And just as much innovation is going on on the consumer side. So, if you can’t tell me where generation is going to be, if you can’t tell me what load is going to be at any one substation, how could a utility possibly predict what their grid needs going forward?” he asked.

“What we’ve really done is built a system that takes three to five years to make the simplest of decisions because we treat every decision as though it is a 30-year investment and that you have 30-year information on what your grid is going to look like, and that’s simply not the world we live in anymore,” Rotenberg said.

Kelly Speakes-Backman, Energy Storage Association | © RTO Insider

Kelly Speakes-Backman, CEO of the Energy Storage Association, said focusing exclusively on the short term is not realistic. “You have to think about long-term investments because these are really large investments.”

“I totally agree,” Rotenberg responded. “When you have to think long term, let the market compete for who’s going to make that long-term investment.”

Changing TOs’ Incentives

Rotenberg said utilities in Europe and Australia have been quicker to adopt advanced transmission technology by his company and others because they have ratemaking rules that allow their utilities to share in savings. In most of the U.S., by contrast, utilities’ rate-of-return structures incent them to spend more on expensive transmission upgrades. Rotenberg said seven of the top 11 utilities in the U.S. have nonetheless adopted his company’s power flow “valves” and should be regarded as “heroes” because the technology will reduce their earnings.

Susan Pope, FTI Consulting | © RTO Insider

Susan Pope, managing director of FTI Consulting, agreed with Rotenberg on the need for change. “If a battery is the cheapest way to ensure service to a customer at the long end of a transmission line, we shouldn’t be building wires,” she said.

Pope said she fears the pace of technological change may result in a new episode of stranded costs.

“I’m concerned that we get state-level initiatives that are going to be investing in technologies or in projects that are not justified on a market basis. And somebody’s got to pay for that. That’s going to end up being shareholders in terms of stranded costs, or I think it’s going to be small customers because … large customers find a way to avoid paying those large fixed costs. If they’re levied based on peak usage, for example, what you’re seeing in Ontario is customers are increasing their demand in peak hours so that they can meet the threshold so that they can bypass transmission charges.”

MISO Tariff Changes Target Cybersecurity Data Sharing

By Amanda Durish Cook

CARMEL, Ind. — MISO has drafted proposed Tariff changes that would allow it to share more information on significant cyberattacks with the federal government.

The revisions, targeted for FERC filing early next year, will permit emergency data sharing with the Department of Homeland Security should MISO experience a cyberattack.

David Rosenthal | © RTO Insider

“Right now, we’re very limited in the information we can share,” David Rosenthal, director of incident response and systems recovery, said during a Nov. 1 Reliability Subcommittee meeting. MISO’s Tariff currently permits data sharing with FERC and the Commodity Futures Trading Commission.

MISO is a Section 9 entity according to President Barack Obama’s 2013 Executive Order 13636, which means it’s on a shortlist of entities with critical infrastructure at greatest risk that the government is interested in protecting.

Last year, President Trump signed Executive Order 13800, which tasked DHS with measures that federal agencies could use to support cybersecurity efforts of Section 9 entities.

MISO is also waiting to see how complicated the new NERC standard CIP-008-6 will be; the rule requires reliability coordinators to report attempts to breach cybersecurity. A comment period for the standard closed on Oct. 22.

In anticipation of these activities, MISO has drawn up Tariff revisions for data sharing with “federal agencies with responsibilities for cybersecurity in response to cyber exigency.”

“Honestly, we truly only plan to use this in a significant event like a blackout or a nuclear event,” Rosenthal said. “MISO hopes to never need to use the additional data-sharing practices.”

Staff said the ambiguity around which federal agencies MISO can share data with is deliberate, providing the RTO the latitude to share information with other federal entities with cybersecurity responsibilities, such as the FBI, in the event that DHS is overloaded following a mass attack.

“We just don’t want to pause while we’re in the middle of an incident to see which federal agencies are listed in the Tariff,” Rosenthal said.

He stressed that the information sharing can only be authorized by MISO’s chief information officer or chief information security officer. The RTO will be authorized to terminate the agreement at any time.

The Tariff revisions will also include a confidentiality request that federal agencies not share MISO’s information with third parties. Rosenthal said this aligns with current information-sharing practices with FERC and CFTC, agencies that also do not guarantee confidentiality, though the RTO nevertheless includes confidentiality requests in those agreements as well. Staff promised to make use of whatever authority available to MISO to limit the spread of its information.

MISO requests feedback on the data-sharing proposal by Nov. 21. Rosenthal said MISO would try to file in January.