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November 1, 2024

IPL, MidAmerican: MISO Misallocating Upgrade Costs in GIA

By Michael Brooks

Two Midwest load-serving entities are challenging a generator interconnection agreement filed by MISO that they say would result in one company paying too much for $5.7 million in transmission upgrades because the RTO is misapplying a provision in its Tariff.

Marshalltown Generating Station (Alliant-Energy) IPL, MidAmerican Energy, MISOInterstate Power and Light (IPL), which is building the 650-MW Marshalltown Generating Station in Iowa, joined MidAmerican Energy last week in protesting the GIA that MISO filed for the combined cycle plant. The companies told FERC that MidAmerican would end up paying the majority of costs for the transmission upgrades in the agreement, while IPL would only pay the installed cost of capital of the shared network upgrades and not its full portion of the monthly facilities charges contained in MidAmerican’s facility service agreements with transmission owner ITC Midwest (EL16-1083).

The upgrades in the Marshalltown agreement were previously included in GIAs filed for two MidAmerican wind farms. ITC had elected to fund the upgrades itself and agreed with MidAmerican that if they became shared upgrades, ITC would determine each interconnection customer’s cost responsibility for them.

Instead, the companies said, MISO believes that Attachment FF of its Tariff requires IPL to make a one-time cost of capital payment to MidAmerican. The companies argued that Attachment FF only applies to when an interconnection customer, not the TO, is funding the upgrades.

“The MISO Tariff language is silent regarding the instant situation, where ITC Midwest as the transmission owner elected to self-fund the network upgrades,” IPL and MidAmerican said. “MISO has refused to recognize the difference between a situation where the first interconnection customer funded the shared network upgrades and the situation here where the transmission owner self-funded” them.

“The distinction is important because … MISO’s requirement that the second interconnection customer simply make a one-time payment for the cost of the shared network upgrades to the first interconnection customer results in unequal and inequitable treatment of the two interconnection customers for the same upgrades,” the companies said.

The companies said IPL should pay 32% of the costs for a $2 million transformer upgrade and 51.4% for a $3.72 million line rebuild. They asked FERC to order MISO to revise the Marshalltown GIA to reflect these cost allocations.

“Parties should be paying their fair share,” Cortlandt C. Choate Jr., senior attorney for IPL parent company Alliant Energy, said in an interview.

They also asked that MISO be required to revise its Tariff to clarify interconnection customers’ cost responsibilities for upgrades funded by the TO.

SPP Briefs: New Trustee Chairman, Wind Record

The SPP Regional Entity trustees elected Dave Christiano as their new chairman during a special board meeting last week, replacing the resigned John Meyer.

Dave Christiano
Christiano Source: SPP

Meyer announced his resignation the week before, during the SPP RE’s spring workshop in Little Rock, Ark. Because there are only three RE trustees, Christiano and Gerry Burrows moved quickly to “expedite” Meyer’s replacement, they said in an email to members.

During the March 22 call, Burrows nominated Christiano for chairman, then joined him in a 2-0 vote.

Christiano told members the RE doesn’t expect to fill Meyer’s vacancy until July at the earliest. The Russell Reynolds Associates executive search firm has been contracted to help.

“Gerry and I decided we couldn’t go four months without a chairman,” Christiano said.

Alluding to Meyer’s nine years as chair of the RE trustees, Christiano told members they will see little change.

“I will pledge, and I’m sure Gerry will pledge too, that we’re not going to change any directions,” said Christiano, who has been a trustee alongside Meyer since the RE’s inception in 2007.

The RE trustees operate separately from SPP’s Board of Directors, providing oversight of RE decisions on regional standards, compliance enforcement and penalties. Only the trustees and certain RE staff members have the authority to make compliance and enforcement decisions.

An electrical engineering graduate from Clarkson College in New York, Christiano began his industry career with Consolidated Edison in New York City in 1971 and took part in an analysis of the 1977 blackout. He spent 28 years with City Utilities of Springfield in Missouri before becoming an RE trustee. Christiano has served on numerous SPP and NERC boards and committees.

Meyer resigned from the RE because of a conflict with the bylaws of Western Interconnection reliability coordinator Peak Reliability, where he is vice chair. The Western Area Power Administration, which joined SPP last year, is partly in the Western Interconnection, requiring SPP to register with the Western Electricity Coordinating Council as a planning authority and transmission-service provider.

To ensure independence, Peak’s bylaws prohibit its board members from serving on other boards in the WECC.

Christiano said Meyer chose to stay with Peak, where he only has two years of service. “He felt he had a lot more to offer there,” Christiano told RTO Insider.

SPP Sets New Wind Peak Record

The RTO set a new wind peak at 6 a.m. March 21, relying on about 87% of the wind capacity in its footprint to generate 10,783 MW. The previous record of 10,280 MW was set Feb. 17.

The RTO has 12,397 MW of installed and available wind capacity in its footprint, with another 33,819 MW of capacity in various stages of development.

Brown Honored with International Award

SPP CEO Nick Brown will be honored by the University of Arkansas at Little Rock’s (UALR) College of Business for his recent Business Achievement Award from the Beta Gamma Sigma.

The society annually recognizes achievement in business and ethical leadership. The UALR College of Business nominated Brown for the award and will hold an invitation-only reception in his honor in Little Rock. Brown said he was “humbled” by the award and thanked SPPs employees, “who are the foundation of our corporate success.”

Beta Gamma Sigma is an international honor society serving business programs accredited by the Association to Advance Collegiate Schools of Business.

– Tom Kleckner

Texas Commission Approves Oncor REIT Structure

By Tom Kleckner

The Public Utility Commission of Texas on Thursday approved Hunt Consolidated’s proposed acquisition of Oncor, the state’s largest transmission and distribution utility and the most valuable remaining piece of troubled Energy Future Holdings (Docket # 45188).

Oncor Service Territories (PUCT)The PUC’s March 24 order would split Oncor into two companies, one of which would operate as a real estate investment trust (REIT) under the state Public Utility Regulatory Act. The commission gave the parties a Nov. 30 deadline to complete the transaction.

As a REIT, Oncor AssetCo would own the transmission and distribution facilities, while Oncor Electric Delivery Co. (OEDC) would rent the facilities to provide electric delivery services. OEDC would house most of Oncor’s management and employees and the remainder of the assets.

Oncor AssetCo would avoid paying federal income taxes as part of the transaction if it derives at least 75% of the its gross income from property rents. Hunt has taken a similar tack with its Sharyland Utilities, which provides services to 53,000 customers, primarily in West Texas and the Rio Grande Valley.

The commission agreed with the proposal, saying “payments received from OEDC, as the lessee and operator of the assets, will constitute rents from real property under the meaning of the Internal Revenue Code.”

The plan has drawn criticism from a disparate group that includes former Texas Gov. Rick Perry, a coalition of cities served by Oncor, the AARP and PUC staff. Much of the criticism centers on the REIT conversion and whether it would provide a windfall for the company at the expense of ratepayers.

Two Texas state senators, Kelly Hancock and Royce West, called into the meeting to add their objections, saying the REIT should not be able to collect taxes in its rate structure if it doesn’t intend to pay them. The tax benefit is worth about $250 million, and the Hunt group had been looking for a guarantee it could take full advantage of the benefit.

“I am not against the acquisition,” West said from China through heavy static. “I understand a REIT has to distribute [funds to shareholders]. The question in my mind is should [the REIT] be allowed to use dollars earmarked for taxes … to shareholders.”

The commissioners discussed whether to add a separate accounting treatment for the taxes, with one proposal to immediately credit ratepayers $100 million. However, Chair Donna Nelson stepped in to say adding too many restrictions to the deal might make it unmanageable.

“It sounds like you’re punishing them now,” she said. “If we’re going to deny it, why don’t we just deny it? If you’re going to keep attaching these things to it, it’s going to die anyway. All we’re doing is wasting time.”

In the end, the PUC’s order said the tax-savings issue will be “addressed by commission staff and intervenors in the next rate proceeding of Oncor AssetCo and OEDC.”

While siding with Anderson and Commissioner Brandy Marquez on the order, Nelson dissented from the majority’s decision “regarding the timing and treatment of the income tax expense.” Nelson’s position throughout the Hunt-Oncor process has been to oppose customer refunds.

Geoffrey Gay, legal counsel for about 150 cities served by Oncor, said he expects his clients to file rate cases by the end of April, bringing about the rate case a year earlier than the current schedule.

Oncor expects the proposed transaction, “if funded by investors,” to close on or before year-end.

“While there are a number of hurdles left to clear, we look forward to working with the parties involved to reach a conclusion in this change-in-control proceeding,” said Geoff Bailey, Oncor’s director of communications, in a statement.

Hunt did not respond to a request for comment on the order. However, a Hunt representative issued a statement after the PUC meeting saying it would “continue to work with all parties in the EFH bankruptcy proceeding over the coming months to reach a successful closure of the transaction consistent with the order approved today.” The company is a Dallas-based oil and gas, real estate and power company, owned by the wealthy Hunt family.

Oncor delivers power to more than 3 million homes and businesses over about 119,000 miles of transmission and distribution lines in North and West Texas. Determining its fate is central to resolving EFH’s Chapter 11 bankruptcy reorganization, which was filed in April 2014.

EFH was the result of a $48 billion leveraged buyout of TXU Corp. in 2007, when the utility faced strong public opposition to its plan to build 11 coal plants in Texas. Private investors led by KKR and TPG Capital bet on rising energy prices but found themselves instead saddled with $42 billion in debt following the 2008 global financial crisis and plunging gas prices due to the fracking boom.

A U.S. bankruptcy judge in December approved EFH’s plan to split into two separate companies — Oncor and the unregulated power generation and retail arms, Luminant and TXU Energy, respectively — wiping out the LBO sponsors’ equity. The Luminant-TXU Energy businesses would go to senior lenders owed about $24 billion.

The decision assumes creditors would not incur a multibillion-dollar tax bill. The IRS is reviewing whether the transfer of assets to creditors represents a taxable sale.

Federal Briefs

The Nuclear Regulatory Commission sent a letter to the Tennessee Valley Authority outlining allegations of a “chilling effect” at its Watts Bar Nuclear Plant, where control room operators have expressed concerns about raising safety issues. NRC earlier this month said it was looking into the issue, but sending the letter formalizes its intent to investigate.

WattsBarSourceNRC“While we believe TVA management understands these issues, the chilling effect letter documents the NRC concerns and our expectations that TVA fully address them and ensure that all plant employees feel free to raise any safety problems,” NRC Region II Administrator Cathy Haney said in a statement. The letter gives TVA 30 days to respond.

“I think it’s important to note that neither NRC nor TVA have found evidence of any actual retaliation, but both have found that just the perception that retaliation has happened can have the same effect,” TVA spokesman Jim Hopson said. “This is just as serious to us as any type of actual retaliation.”

More: Knoxville News Sentinel

Protesters Arrested at FERC ‘Pancakes not Pipelines’ Event

FERCPancakesSourcePopularResistanceA documentary filmmaker and six others were arrested after they blocked the garage entrance of FERC headquarters to protest a pipeline project that would deliver Marcellus Shale natural gas to Northeastern markets.

Josh Fox, the maker of the anti-drilling film “Gasland,” was part of the protest, in which FERC commissioners were invited to sample pancakes topped with maple syrup produced from trees that were cleared for the Constitution Pipeline in Pennsylvania.

“It is clear to me that FERC has to be the most destructive agency in the United States right now,” said protester and syrup producer Megan Holleran. “They are faceless, nameless, unelected and ignore citizen input.”

More: Beyond Extreme Energy

Circuit Court Gives Sierra Club Chance to Obtain Entergy Records

SierraClubSourceSierraA federal appeals court will allow the Sierra Club to make its case in federal court to obtain records that Entergy supplied to EPA about two Arkansas coal plants and a third plant in Louisiana.

The 5th U.S. Circuit Court of Appeals ruled in favor of the Sierra Club’s efforts to obtain the documents, which concern the 1,700-MW Independence and White Bluff coal plants in Arkansas, which operate without major emission-reducing scrubbers. The third plant is a 30-year-old coal plant near Lake Charles, La.

Glen Hooks, director of the Sierra Club of Arkansas, said his organization uses such emissions documents to monitor whether Clean Air Act violations are occurring. “I don’t think we’re going to have a lot of trouble getting the documents now,” he said.

More: Arkansas Democrat-Gazette

Tennessee Gas Seeks Pipeline Challenge Dismissal

TennesseeGasSourceTGPTennessee Gas Pipeline has asked FERC to dismiss an attempt by an advocacy group to block construction of a 4-mile pipeline spur that cuts through a state-protected forest in western Massachusetts.

The filing opposes a motion by Sandisfield Taxpayers Opposing the Pipeline to prevent immediate tree-cutting. The regulators approved the pipeline project on March 11. The loop is part of a 13-mile, $87 million Connecticut Expansion Project that would provide additional natural gas to three utilities.

The state of Massachusetts is also trying to delay the project, arguing that the state constitution protects the woodlands unless lawmakers grant an exemption, which they have declined to do.

More: The Berkshire Eagle

Energy Companies Bid $156M For Gulf Drilling Leases

BureauOceanEnergyManagementSourceGovThirty exploration companies bid $156 million to lease 128 oil and natural gas tracts in the central section of the Gulf of Mexico. The area covers nearly 700,000 acres 3 to 230 nautical miles off the coasts of Louisiana, Mississippi and Alabama.

While bidding was heavy for the central section, no bids were received for the Eastern Planning Area, according to the Bureau of Ocean Energy Management.

More: World Oil

Feds Approve Research Wind Facility Offshore Virginia

The Bureau of Ocean Energy Management approved construction of two 6-MW wind turbines to be installed 27 miles off the coast of Virginia as part of a research project to test how the turbines hold up under harsh conditions.

“Data collected under this research lease will help us better understand the wind potential, weather and other conditions off of Virginia’s coast,” BOEM Director Abigail Ross Hopper said.

Dominion Resources issued a request for bids for the research turbines last year. The bids came back between $375 million and $400 million, about twice as high as expected, so Dominion delayed the project’s start date from 2017 to 2018. Dominion has a lease on 113,000 acres for offshore wind development.

More: The Associated Press

EPA Believes it has Mapped Extent of Nuclear Waste

epasourcegovRadiation from nuclear waste that was buried in the 1970s has migrated farther than once thought, according to EPA. The waste in the West Lake Landfill near St. Louis comes from uranium processing of material for the Manhattan Project in the 1940s.

EPA said mapping shows some of the waste products seem to be about 600 feet further than thought, but the agency downplayed the risk. “While the footprint of the [radiologically impacted material] has changed … there’s still no significant health risk posed by the radioactive waste at the West Lake Landfill,” EPA’s Brad Vann said.

EPA is mapping the waste as part of an investigation to determine how to build a barrier to contain the material.

More: St. Louis Post-Dispatch

MISO, Stakeholders: Reforms Needed, but ‘Seamless’ Seam an Illusion

By Amanda Durish Cook

MISO stakeholders say they do not expect perfect procedures at the seams with neighboring balancing areas, but they do want the

Robert-Gee-(copyright-RTO-Insider)-web
Gee (with Bloodworth in the background) © RTO Insider

RTO to implement reforms to address price deviations, remove obstacles to interregional transmission projects and improve cost allocation among those projects.

Seams issues were the “hot topic” at last week’s Advisory Committee discussion moderated by consultant Robert Gee.

Remove ‘Triple Hurdle’

Several times during last week’s discussion, stakeholders called for removal of the “triple hurdle” faced by interregional projects, which must meet a specific interregional cost-benefit standard as well as comply with the internal standards of the two RTOs involved.

Stakeholders also repeated a request that MISO and SPP lower the minimum 345-kV requirement for interregional projects. In comments filed ahead of the meeting, the Power Marketer sector noted that of the 300 interconnections between the two RTOs, only 12 meet that standard.

The Competitive Transmission Developer sector recommended that MISO create a new interregional project category with a separate, singular benefit calculation. “MISO should conduct outreach to neighboring regions to advocate for adoption of the proposed interregional criteria in both [joint operating agreements] and in MISO’s regional Tariff as a separate project category,” the sector wrote.

It noted that RTO boundaries are “artificially imposed and do not reflect natural barriers to the flow of power throughout the region.”

MISO-Seams-Progress-(MISO)---content-web

The Environmental Sector urged MISO and PJM to expedite their initiative on targeted market efficiency projects, formerly called “quick hit” projects. The sector also urged MISO to resolve disagreements with other RTOs over the future scenarios that should be studied.

Letting Go

The Independent Power Producers sector predicted a dire future for MISO’s market if the RTO failed to improve its market-to-market locational energy pricing and settlements.

The IPPs said MISO’s “uncompetitive” capacity construct and abundant wind resources would incentivize energy exports. The sector criticized MISO and its Independent Market Monitor for endorsing concepts rejected by other RTOs, such as the proposed two-season capacity construct. It also criticized MISO’s efforts to discourage generators from exporting power under pseudo-tie arrangements with PJM. (See MISO Delays Seasonal, Locational Capacity Constructs.)

“MISO staff and the MISO IMM seem to have a hard time letting go of some of their proposals that have been evaluated and subsequently rejected by their seams partners and their seams partners’ constituents and stakeholders,” the IPPs said.

The Public Consumer sector declined to recommend specific changes but observed that “transmission from region to region … is a major way that [operational] efficiency across seams can be realized.”

The Transmission Dependent Utilities sector said RTOs should improve data exchange to better coordinate outages and update firm flow entitlement calculations. “As additional flowgates are determined to be significantly impacted by the dispatch in neighboring regions and interregional transactions, the modeling detail of neighboring systems must expand,” the sector wrote.

The TDUs also said RTOs should “seek middle ground rather than holding out for the ideal solution” and consider mediating seams issues when necessary.

Chris Plante, of TDU member Wisconsin Public Service, said the best way to improve the efficiency of the seam is to operate seams dispatch from two RTOs as if they were “under a single commitment and dispatch algorithm.”

The Transmission Owners sector wrote in favor of coordinating congestion hedges with other RTOs, improving real-time coordination with SPP and altering generator pseudo-tie requirements to synch with PJM’s market.

MISO Board: Cooperation is Key

MISO Advisory Committee (Copyright RTO-Insider)
MSIO Advisory Committee © RTO Insider

MISO officials and stakeholders generally agreed that better interregional cooperation is essential to addressing seams issues but opinions varied about what to expect from that cooperation — and what outcomes are actually desirable.

NRG Energy’s Tia Elliot pointed out that MISO struggles with project cost allocation even among its own stakeholders. “I think it could be difficult when it comes to interregional planning,” she said.

Calpine Vice President of Market Design Brett Kruse advocated “reasonable expectations with the guy on the other side of the seam,” noting that RTOs will not have identical cost allocations and flowgates. “The other RTOs have already considered [other market operations], determined it’s not for them and moved on,” he said. “It’s best to leave that stuff alone and work on the common areas.”

FERC Action Needed?

MISO Chair Judy Walsh asked, “We know the problem … but are [RTOs] going to be able to work this out, or is it going to take FERC stepping in and ordering this for the common good? Are we kidding ourselves that we will be able to work this out?”

“Your question, I think, is right on target,” Plante replied. “Now we’re dealing with topics and issues that are heavily ingrained in each RTO’s process.” He said mutual respect for different market implementations will be instrumental in “bridging the gap.”

Director Phyllis Currie said RTOs must seek compromise. “What I’m hearing here is not that different from what I’ve heard in California … and I’ve seen it over the years across different industries,” she said. “If everybody keeps coming at the problem the same way they’ve come at the problem time and time again, you don’t get anywhere.”

Megan Wisersky of Madison Gas and Electric said RTOs should not be required to have uniform rules. “I say, vive la différence!”

“My takeaway is we may not ever get to the idea of a seamless seam, but that shouldn’t dissuade us,” said board member Thomas Rainwater.

Plante agreed. “A seamless seam is an oxymoron,” he said.

Retailers Ask for Rehearing of NY Guaranteed Savings Order

By William Opalka

Electricity retailers in New York on Friday asked for rehearing of an order that would overhaul retail customer choice in the state.

The Impacted ESCO Coalition and the National Energy Marketers Association separately asked for a rehearing of the New York Public Service Commission’s Feb. 23 order that mandated customer savings under most contracts (98-M-1343).

The order mandates that customers be guaranteed an electric rate lower than what their host utility offers, with the exception of “green” offerings that must include a minimum of 30% renewable energy. The commission said the order was intended to combat deceptive practices and boost consumer confidence. (See Zibelman: Rules Meant to Enable Markets.)

The retailers say the reforms were ill-considered and hastily enacted. “Contrary to well established commission policy and practice in support of the development of competitive retail markets, and without notice or meaningful opportunity to be heard, the February order adopted requirements for ESCO [energy service company] service to mass market customers, which would effectively shut down the market for the majority of ESCOs and their customers,” the NEMA wrote.

The PSC had required ESCOs begin compliance within 10 days, or March 3. However, a state court stayed the order, scheduling a show-cause hearing for April 14. (See Court Delays New York ‘Guaranteed Savings’ Rules.)

Among the complaints by the ESCOs is that the rules were enacted without adequate notice under the State Administrative Procedures Act and that the price guarantee is improper rate-setting by the PSC.

The NEMA also said the order amounts to an illegal taking of its members’ accounts. “All of the ESCOs that cannot comply with the order will be forced to give their hard-won customers, which the ESCOs incurred significant costs to acquire, to the competing monopoly utility. The utilities will unfairly acquire these ESCO customers for free,” it wrote.

“The improperly noticed rules represent a sweeping set of changes that threaten to destroy hundreds of businesses and affect millions of New York residents,” wrote attorneys for the IEC, which describes itself as representing “small to medium” ESCOs, many of whom who operate primarily in New York.

New England ROEs Set in Initial Decision

By William Opalka

A FERC administrative law judge last Tuesday set the return on equity for transmission projects over two periods in New England lower than what transmission owners sought but higher than what states and commission trial staff advocated.

Recommended Base Return on Equity (ROE) - FERC, New EnglandThe 371-page initial decision by Judge Steven Sterner lowered the base and ceiling ROEs for the New England Transmission Owners to 9.59 and 10.42% respectively for December 2012 to March 2014 and set the range at 10.9 to 12.19% for July 2014 through October 2015 (EL13-33, EL14-86).

The decision came in a consolidation of two complaints initiated by state officials against the New England TOs: Eversource Energy, Central Maine Power, National Grid and NextEra.

The case was heard under the new framework FERC set in its June 2014 ruling that switched to a two-step discounted cash flow (DCF) model incorporating short-term and long-term growth rate estimates (EL11-66-001, Opinion 531).

The TOs had sought a base ROE of either 10.24 or 11.14% for the period ending March 2014 and a maximum of 11.14% for the later period. The states had sought 8.75% and 8.16%.

Sterner held an evidentiary hearing last June and July. (See Hearing over New England Transmission ROE Nears End.) A decision was expected by the end of the year, but Sterner on Dec. 18 ruled there was “was insufficient evidence in the record from which he could establish a zone of reasonableness” because no parties had performed the DCF methodology in accordance with Opinion 531.

After the calculations were rerun, FERC staff recommended a base ROE of 8.68 or 8.74% for the 2014/15 timeframe.

The states and FERC staff contended the recovery in the stock market made the TOs more attractive to the investment community and that capital markets were returning to more normal conditions.

Sterner rejected their arguments. “The evidence shows that the same types of anomalous capital market conditions that existed [before December 2012]” prevailed in the time periods of the cases, “distorting the inputs to the DCF model,” he wrote.

“Alternative benchmark methodologies show that the midpoint of the DCF range of reasonableness would not be a just and reasonable base ROE for the NETOs. Under these circumstances, a mechanical application of the DCF model will not satisfy regulatory standards and an upward adjustment from the midpoint of the zone of reasonableness is necessary in order to comply with” Supreme Court precedent, Sterner wrote.

What about April, May, June 2014?

PJM Markets and Reliability and Members Committees Preview

Below is a summary of the issues scheduled to be brought to a vote at the Markets and Reliability and Members committees Thursday. Each item is listed by agenda number, description and projected time of discussion, followed by a summary of the issue and links to prior coverage in RTO Insider.

RTO Insider will be in Wilmington, Del., covering the discussions and votes. See next Tuesday’s newsletter for a full report.

Markets and Reliability Committee

2. PJM Manuals (9:10-9:30)

Members will be asked to endorse the following manual changes:

  1. Manual 1: Control Center and Data Exchange Requirements. Adds new section for planning, coordination and notification of system changes and events, with updated procedures. New Attachment C is the new Inter-control Center Communication Protocol (ICCP) failover test plans diagram. Removes references to the PJM ICCP network interface control document and PJM ICCP communications workbook.
  2. Manual 6: Financial Transmission Rights. Housekeeping changes resulting from annual review. Clarifications better describe existing rules and processes.
  3. Manual 11: Energy and Ancillary Services. Changes implement Capacity Performance rules regarding unit-specific parameters. For base capacity resources, the status quo remains until 2018. For CP resources, beginning in delivery year 2016, unit-specific parameters will apply during hot weather alerts, cold weather alerts, emergency actions and when being offer-capped to maintain system reliability.
  4. Manual 11: Energy and Ancillary Services Market Operations. Revisions reflect day-ahead market timeline changes. Among them: effective Friday, the deadline for submitting day-ahead bids will be 10:30 a.m. The day-ahead clearing window will be reduced to three hours. The deadline for posting day-ahead results will be 1:30 p.m. or as soon as practicable. Results will be posted upon approval but not before noon.

3. Confidential Market Data Postings (9:30-9:45)

Manual 33: Administrative Services for PJM Interconnection Agreement. Changes provide six exceptions for when PJM may release market data. (See “Market Data Confidentiality Rule Change Gets First Reading,” Market Implementation Committee Briefs.)

4. Operating Parameter Definitions (9:45-10:15)

Manual 11: Energy and Ancillary Services Market Operations; Manual 15: Cost Development Guidelines; and Manual 28: Operating Agreement Accounting. Revisions define operating parameters. (See “Operating Parameter Definitions Approved,” PJM Market Implementation Committee Briefs.)

5. Performance Assessment Hour Ramp Rate (10:15-10:45)

Revisions to Tariff and Manual 18: PJM Capacity Market offer an interim solution to the performance assessment hour ramp rate.  (See “Ramp Rate for CP Approved,” PJM Operating Committee Briefs.)

6. Regional Transmission and Energy Scheduling Practices (10:45-10:55)

Proposed revisions to regional transmission and energy scheduling practices reflect PJM’s adjustment to its day-ahead energy market timeline.  (See “Day-ahead Submission Deadline Moved up,” PJM Market Implementation Committee Briefs.)

7. Governing Documents Enhancement & Clarification Subcommittee (GDECS) (10:45-11:05)

  1. Members will be asked to approve updated definitions and clarifications to PJM’s governing documents. They involve the terms PJM board, market participant, credit breach, PJM region, regional entity, affiliate, PJM markets, economic minimum and transmission customer.

Members Committee

CONSENT AGENDA (1:20-1:25)

  1. Members will be asked to approve revisions to governing documents related to updated definitions developed by the GDECS.

ENDORSEMENTS (1:25-1:55)

  1. GOVERNING DOCUMENTS ENHANCEMENT & CLARIFICATION SUBCOMMITTEE (GDECS) (1:25-1:35)

  2. Members will consider proposed changes to governing documents as well as additional clarifications to previously endorsed revisions.
  3. Members will be asked to endorse Tariff and Operating Agreement revisions regarding the definition of the term counterparty. In an Aug. 27 Members Committee vote, the word counterparty was removed from a batch of proposed definitions and returned to the GDECS for further review at members’ request. The definition was aligned to use more precise language in the OA that specifies when PJMSettlement will and will not be a counterparty to a transaction or agreement.
  4. CAPACITY PERFORMANCE IMPLEMENTATION (1:35-1:45)

See MRC item 5 above.

  1. OPERATING PARAMETER DEFINITIONS (1:45-1:55)

See MRC item 4 above.

MISO Redesign Nears Completion

By Amanda Durish Cook

NEW ORLEANS — MISO’s stakeholder redesign is complete — or nearly so, according to committee members close to the project.

MISO Steering Committee © Copyright <em>RTO Insider</em>
At the meeting © RTO Insider

“We have gotten through what I would consider to be a complete transition,” Steering Committee Chair Tia Elliott, of NRG Energy, said during last week’s board meeting. “Quite a bit of streamlining has taken place.”

Audrey Penner, chair of the Advisory Committee, said the redesign was about 90% complete.

Continuing that work, the Steering Committee unanimously supported a motion to retire the Pseudo-Tie Issue Task Team. MISO Director of Market Engineering Kim Sperry said the team had fulfilled its objective of framing pseudo-tie issues and passing them along to other working groups. Sperry said that those issues will be taken up in the Joint and Common Market meetings between PJM and MISO, while related market topics will be addressed at future Market Subcommittee meetings.

miso retirements - stakeholder redesign entity transitions

Other highlights of the redesign:

  • With the retirement of the Data Transparency Working Group, the Steering Committee will take over responsibility for recommending which MISO group should handle data requests. (MISO will retain final say.) Working group liaison Tom Welch said two of the five data issues that remain open will be concluded in the first week of April, when MISO is expected to begin posting final five-minute real-time market clearing prices and historical five-minute real-time ex ante LMPs and MCPs.
  • Steering Committee members approved the Credit Settlements Working Group charter and management plan. The newly formed group will hold its first quarterly meeting in Carmel, Ind., on May 12.
  • The Resource Adequacy Subcommittee has elected Madison Gas and Electric’s Gary Mathis and Wisconsin Public Service’s Chris Plante to serve as chair and vice chair, respectively. The RASC replaces MISO’s former Electric and Natural Gas Coordination Task Force and the Demand Response and Loss of Load Expectation working groups.

How a ‘Phantom Mouse’ and Weaponized Excel Files Brought Down Ukraine’s Grid

By Rich Heidorn Jr.

Sometime last spring, employees of three Ukrainian electric distribution companies opened Microsoft Office files infected with BlackEnergy 3 malware. It was the beginning of a six-month campaign of reconnaissance and testing that culminated Dec. 23 with an outage that knocked out power to 225,000 customers for several hours.

Word-File-Infected-with-Malware-(NERC,-SANS-ICS)-webThe story of the cyberattack — the first publicly acknowledged assault to cause power outages — was spelled out in riveting detail in a report released last week by NERC’s Electricity Information Sharing and Analysis Center.

The Security Service of Ukraine blamed the attack on the Russian government. But the report, the product of NERC’s E-ISAC and the SANS Institute, focused on the methods of the attack and not on identifying the attackers.

Based on a summary of publicly available information and analysis performed by the SANS Industrial Control Systems unit, the report contains recommendations for defending grid operations.

The report’s authors express also grudging respect for the expertise of the hackers. “The strongest capability of the attackers was not in their choice of tools or in their expertise, but in their capability to perform long‐term reconnaissance operations required to learn the environment and execute a highly synchronized, multistage, multisite attack,” the report said.

Spear Phishing

The report estimates that the blackouts came more than six months after the initial penetration of the companies, when employees in the administrative or information technology networks of the electric companies opened Microsoft Excel and Word documents from spear phishing emails.

Rogue-Client-Used-'Phantom-Mouse'-(NERC,-SANS-ICS)-webThe employees enabled macros in the files that allowed the installation of BlackEnergy 3 malware on the companies’ systems, providing access to command and control Internet Protocol addresses.

After gaining a foothold in the companies’ IT networks, the hackers were able to obtain credentials that gave them access through virtual private networks (VPNs) to the industrial control systems (ICSs). The report said the hackers demonstrated expertise in network-connected infrastructure and in operating the ICSs.

They used “rogue” client software and a “phantom” mouse to highjack the supervisory control and data acquisition (SCADA) systems remotely, taking control of operator workstations and locking the operators out of their systems.

Kyivoblenergo, a regional electricity distributor in Ukraine, was one of the three “oblenergos” (energy companies) attacked. Beginning about 3:35 p.m. on Dec. 23, the hackers took remote control of the company’s SCADA distribution management system, disconnecting seven of its 110-kV substations and 23 35-kV substations for three hours and cutting off power to about 80,000 customers.

Similar attacks on the other two companies, executed within minutes of each other, blacked out an additional 145,000 customers.

Burning the Bridges

KillDisk software was used to erase the master boot record of the companies’ systems and delete some logs, preventing the companies from using the ICSs to restore the system. The attackers also uploaded malicious firmware to serial‐to‐Ethernet gateway devices, ensuring that even if the operator workstations were recovered, remote commands could not be used to bring the substations back online.

“This means that the attacker ‘burned the bridges’ behind them by destroying equipment and wiping devices to prevent automated recovery of the system,” the report said.

The attackers also generated thousands of automated phone calls to the call center of one of the companies — a version of a denial-of-service attack — to hamper communications with customers.

With their computer systems compromised, field staff went to substations and manually reclosed breakers, restoring all of the customers to service in three to six hours.

NERC, cyberattack

“It is important to note that there are risks operating your system without the benefit of an automated dispatch control center, and utilities that are more reliant on automation may not be able to restore large portions of their system this way,” said Michael Assante, SANS Institute director of ICSs and one of the report’s authors, in a January blog post. “In many ways, the Ukrainian operators should be commended for their diligence and restoration efforts.”

Missed Opportunities

While the report’s authors found the companies’ restoration admirable, they had plenty to criticize, saying the utilities missed opportunities to detect the intrusion during the months of reconnaissance and testing that preceded the attack.

According to the report, the companies’ firewalls allowed the adversaries to exercise remote control, and the VPNs from their business networks into the ICSs appeared to lack basic two‐factor authentication; think cash machines, which require both a bank card and a personal identification number.

The companies also appeared to lack the capability to continually monitor their ICS networks for increased traffic that could indicate rogue firmware updates, the report said. “In a prolonged attack campaign, there are likely numerous opportunities to detect and defend the targeted system.”

Why the three oblenergos were targeted is unclear, but John Hultquist, director of cyberespionage analysis for computer security firm iSight Partners, said he believes the attacks were the work of hackers aligned with the Russian government. He told The Washington Post that there are links between the malware used in the attacks and a cyberespionage campaign against NATO and Western European governments by a group of Russian hackers iSight named “SandWorm.”

iSight said it has documented SandWorm infiltrations of Ukrainian government computer systems and telecommunications and energy companies since 2014, when Russia annexed Crimea in support of separatists in eastern Ukraine.

Recommendations

How-Cyberattack-Shut-Down-Ukrainian-Power-Cos-(NERC,-SANS-ICS)-webThe report concludes with a number of recommendations, including eliminating unnecessary VPN pathways and developing “cyber blackstart” capabilities. But it warns that “it is likely that the adversary will modify attack approaches in follow‐on campaigns and these mitigation strategies may not be sufficient.”

Some analysts were initially skeptical of the Ukrainian government’s claims that the outages were the result of cyberattacks. “ICS organizations frequently have reliability issues and incorrectly blame cyber mechanisms such as malware found on the network that is unrelated to the outage,” the report said.

In this case, however, the report’s authors had no doubt about the credibility of the government’s and utilities’ claims. It also ranked the technical information available a 4 on a scale of 5, citing the availability of malware samples, observable ICS impacts, technical indicators and firsthand interviews.

The attack marks “the first time the world has seen this type of attack against [operational technology] systems in a nation’s critical infrastructure,” the report said. “This is an escalation from past destructive attacks that impacted general‐purpose computers and servers (e.g., Saudi Aramco, RasGas, Sands Casino and Sony Pictures).”

The report said there was nothing about Ukraine’s infrastructure that made it uniquely vulnerable.

“The impact of a similar attack may be different in other nations, but the attack methodology, tactics, techniques and procedures observed are employable in infrastructures around the world.”