Search
`
July 31, 2024

Microgrids: Evolutionary or Disruptive? That Depends on Who’s Talking

By Suzanne Herel

ATLANTIC CITY, N.J. — The eye of Superstorm Sandy swept over this city nearly three years ago, leaving 2.8 million residents without power. That made the Borgata Hotel Casino a fitting spot to debate the value and challenges of microgrids, Richard Mroz, president of the New Jersey Board of Public Utilities, told a group at PJM’s biannual General Session.

microgrid
Princeton was able to supply its most crucial power needs from on-site generation after losing purchased grid power during Superstorm Sandy.

“Sandy had a cascading effect on all critical systems,” he said, highlighting their interdependency and the role microgrids could play in strengthening their resiliency against natural, accidental and manmade threats.

microgrid
Richard Mroz, NJ BPU

“It’s resulted in debates over the grid — the role of generators, distribution companies and regulators,” he said. “It’s a discussion worth all of our efforts.”

Joined for a roundtable on just that topic were Michael Burr, director of the Microgrid Institute; Lawrence Jones, North America vice president for utility innovations and infrastructure for Alstom; Micah Kotch, director of the New York Prize program at the New York State Energy Research and Development Authority; Thomas Nyquist, executive director of engineering and campus energy for Princeton University; and Thomas Fenimore, technology development manager for Duke Energy.

‘Nested’ Microgrids

Centralized grids are reliable but not resilient, Burr said. That’s where distributed energy technologies can step in.

microgrid
Michael Burr, Microgrid Institute

In particular, he pointed to a trend of “nested” microgrids, where critical facilities such as hospitals and water towers that are located in different areas of town can be served by a cluster of “nodes.”

One such community is the Olney Town Center in Montgomery County, Md., part of a U.S. Department of Energy technology research program to study microgrid models. When completed in the fall of 2016, the community’s six nodes will operate together during normal conditions to maximize economic efficiency and “island” during outages to preserve resiliency.

However, there are challenges to such a model, he said. The nested architecture contains more points of coupling, requiring more interconnection and safety equipment, Burr said. In addition, non-critical loads must be disconnected during islanding.

Princeton Keeps the Lights On

Nyquist brought to the table Princeton University’s experience operating two generators on campus to serve the school’s need for power for labs and data centers. During Sandy, it was this energy independence that saved 50 years’ worth of DNA research, he said.

Princeton uses energy from the PJM grid at night, when the prices are lowest, and generates its own power during the peak period.

“We save a lot of money doing this, but it also reduces load on the grid,” he said.

microgrid
Micah Kotch, NYSERDA

Kotch likened the innovation erupting in the energy industry to the disruption that tech companies such as Uber, Facebook, Alibaba and Airbnb have effected in their spaces — none owns a product, but they’re providing services that have eclipsed their brick-and-mortar competitors.

“Thomas Edison would be the first to agree that energy isn’t about moving commodity but delivering services,” he said. “Utilities have traditionally thought their business ends at the meter. That notion is fundamentally trying to change. There is this customer pull — not a top-down push — for more control.”

Outgoing PJM CEO Terry Boston agreed. “I think choice and control are going to drive microgrids as much as economic viability,” he said.

Energy as a Service

Jones also spoke of the idea of rethinking energy as a service.

microgrid
Lawrence Jones, Alstom

“If kilowatt-hours are not selling, if they’re reducing … how do we evolve from a kilowatt-hour approach to more of a service model?” he asked.

He recounted the experience of one African region where residents were so used to the government subsidizing electricity that they were unwilling to pay for it. What they valued, however, was refrigeration — so they paid more for that in a bundle of services, which made up for the low price of electricity.

Such a paradigm change, Jones said, is where regulators must get involved.

Other core issues, he said, are whether microgrids can benefit the overall transmission system and how to quantify the value of distributed energy.

“How will the markets evolve?” he said. “How do we unlock the value of distributed resources? Do we keep the assumptions we’ve had?”

As for whether microgrids are considered evolutionary or disruptive, “It’s all relative to who you’re talking to,” he said, and depends on where you are in the world.

Value

microgrid
Thomas Fenimore, Duke Energy

Fenimore, of Duke Energy, echoed some of Jones’ questions.

“We know how to operate and build these assets,” he said. “How do we integrate these newer technologies … and then how do we understand in a regulated space what the value of that is on the market side?”

To address the changing landscape, Duke in 2014 created the Distributed Energy Resources Group. Fenimore highlighted the company’s energy storage efforts, which charge and discharge based on market signals to help maintain grid stability.

Boston, who did his graduate thesis on the optimization of energy storage, applauded the project.

“I’m for storage,” he said, adding, “I did learn something today, and that was about the innovation and change that are inevitable here.”

PJM Ponders Changes to Virtual Trades, DA Market

By Rich Heidorn Jr.

ATLANTIC CITY, N.J. — PJM officials and the Independent Market Monitor are considering changes to the treatment of virtual transactions to reduce uplift and gaming opportunities and allow quicker solving of the day-ahead energy market.

PJM Executive Vice President for Operations Mike Kormos and Market Monitor Joe Bowring floated ideas for potential changes during a Year in Review presentation at the PJM Annual Meeting at the Borgata Hotel Casino last week.

pjm
Mike Kormos gives the Year in Review presentation at PJM’s Annual Meeting. © RTO Insider

Bowring suggested PJM consider NYISO’s model, which limits virtual transactions to zones or hubs. Kormos said the RTO could consider either removing the financial transactions from the day-ahead market or making the day-ahead a pure financial market.

In interviews afterward, Bowring and PJM officials said the changes could address uplift and allow quicker solving of the day-ahead market to reduce the disconnect with gas trading schedules.

NY Model

Bowring made his suggestion first, saying PJM might benefit from adopting NYISO’s treatment of virtual transactions — increment offers (INCs), decrement bids (DECs) and up-to-congestion transactions. “Should that be a secondary derivative market or in the PJM market?” he asked.

He said virtual transactions were introduced into the market to improve efficiency. “I think we’ve gone well past that now,” he said, saying they affect unit dispatch and commitments and cause congestion. “I haven’t come to a full and final opinion on this, but questions need to be asked,” he added.

Bowring said his primary motivation for wanting to change the treatment of virtual transactions is to reduce gaming opportunities. “The ability to manipulate the market … would be substantially reduced by limiting financial transactions to zones and hubs or putting them all in a secondary market where they do not affect the actual operation of the market,” he said.

Executive Vice President for Markets Andy Ott said Bowring’s suggestion is “something we need to look at.”

pjm
Andy Ott © RTO Insider

Ott said large volumes of virtual trades are “dumped into the market” because there’s no cost for doing so. Although most do not clear, the large volumes slow processing time for the RTO’s security constrained economic dispatch.

Kormos made his suggestion in response to questions after Bowring’s presentation. “It’s the blending of the physical and the financial that’s causing the uplift” and making the market more difficult to solve, he said.

If the day-ahead market became purely financial, the reliability assessment and commitment (RAC) run could determine the day–ahead schedules for generators, said Mike Bryson, executive director of system operations.

Eliminating physical generation from the day-ahead market could aid efforts to post day-ahead results sooner, Kormos said. A market with no generator minimum run times “would solve a lot faster,” he said.

Under the current system, Bryson said, virtual trades can hurt reliability by masking transmission congestion.

An increment offer — an offer to sell to the day-ahead market if prices go above a specified price — can act like a dispatchable resource. But transmission constraints that are “solved” financially by virtual trades remain in the physical market, Bryson said. “In real time there wasn’t truly a generator there.”

Any changes would be subject to stakeholder review to determine their impacts. For example, limiting virtual transactions to only zones and hubs would prevent them from using generation buses, reducing their value as hedges for generation.

Gas-Electric Scheduling

Ott said PJM hopes to reduce the day-ahead market solution to three hours from the current four-hour average in time for the Federal Energy Regulatory Commission’s April 1, 2016, deadline for changes to gas-electric scheduling. (See PJM Considering Change to Day-Ahead Deadlines in Response to FERC Gas Schedule Order.)

pjm

PJM officials are considering parallel processing and sequencing changes to speed the market solution. Ott said further reductions would not be “feasible” in the next year.

Bowring said the 85% reduction in UTC trading since FERC suggested the transactions might be subject to uplift charges had contributed to a recent reduction in the processing time required for the day-ahead market. (See FERC Issues Request for Comments in UTC Uplift Docket; Ruling by October.)

Ott demurred. “Before we jump to conclusions, we have to see what is the cause of the day-ahead market running faster,” he said.

PJM currently posts its day-ahead results at 4 p.m. The time required to solve varies from day to day depending on factors such as transmission outages and load projections. Most days it takes three to three and a half hours. But some days can take more than four hours, according to a PJM analysis that will be presented at Thursday’s Markets and Reliability Committee meeting.

“Some days you’re bringing it all [generation] on or you’re hardly bringing anything on,” and solution is easier, Kormos said.

Ideally, Kormos said, PJM would like to post its results by 1 p.m. ET, an hour before the first gas nomination deadline at 2 p.m.

Members Polled

PJM is compiling the results of a poll that closed May 18 to gauge members’ preferred response to the FERC order.

The poll asked members which day-ahead market start time would allow them adequate time to construct their offers, with choices ranging from 9:30 a.m. to 11 a.m. It also asked preferences on posting times to provide sufficient time to purchase fuel, offering choices between 1 p.m. and 2 p.m.

Because FERC declined to change the start of the gas day, however, RTO officials say there is no escaping some uncertainty. Other RTOs are wrestling with the same dilemma. (See SPP Trying to ‘Balance the Risk’ on Gas-Electric Schedules.)

“In [either the gas or electric] markets you have to commit before you have your numbers locked up,” Kormos explained.

NYPSC Rejects Renegotiation on Biomass Contract

By William Opalka

New York regulators on Wednesday declined for the third time to renegotiate a contract with a financially troubled biomass generation plant, saying that doing so would threaten the integrity of the state’s renewable energy procurement program.

niagaraIn 2007, the 51-MW co-firing Niagara Generating Facility (NiGen) in Niagara Falls won a $21.6 million contract to provide up to 180,500 MWh of energy per year from renewable-eligible biomass for 10 years. The contract was awarded under the main tier of New York’s renewable portfolio standard following a competitive bidding process.

Sterling Energy Group, which purchased the NiGen plant in 2013, mothballed it in August 2014, saying the fall in wholesale energy prices had left it unprofitable despite its $11.99/MWh in RPS incentives.

Sterling told the New York Public Service Commission it should be given extra credit for increased clean energy generation because it is now able to generate 80% of its power from wood products, without burning tires, which had previously represented 40% of its fuel. The company said the change increased its RPS-eligible generation and reduced harmful emissions.

The petition had won backing from local elected officials who said the plant’s closing would result in the loss of 100 direct and indirect jobs and more than $10 million in local spending. In its mothballed status, the plant has 26 part-time employees.

But the commission was unmoved, saying that Sterling knew of the plant’s shaky finances when it acquired it (03-E-0188).

“The petitioners have requested that the commission provide additional financial incentives that it has twice denied in the past and the commission does not see any significant material differences in this request that compels the reversal of earlier decisions,” the PSC wrote.

“The contract was awarded under a competitive solicitation at a price chosen by NiGen and for the term of years chosen by NiGen. Adjusting NiGen’s RPS benefits would undermine the competitive nature of the solicitation process established by the commission for the main tier.”

Instead, the commission said Sterling should bid its additional renewable capacity into future main tier solicitations.

The plant is permitted to burn coal, tires and various wood-based fuels, but it only receives RPS incentive payments for the amount of generation produced by agricultural residue, wood and other eligible biomass.

PJM Markets and Reliability Committee Preview

Below is a summary of the issues scheduled to be brought to a vote at the Markets and Reliability Committee on 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 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:

A. Manual 36: System Restoration — Annual review. Adds detail about when PJM assumes control and when it returns to normal operation. Also adds guidance on completion of interconnection checklist. Effective: June 15.

B. Manual 03: Transmission Operations — Updates index and operating procedures for PJM RTO operation (nuclear station voltage limits, operation procedures with neighboring systems and operation procedures for AEP, ComEd, Dominion, PPL, UGI, PSEG and PECO.) Effective: June 1.

C. Manual 38: Operations Planning — Makes minor changes due to system upgrades and specifies periodic review of IROL facilities. Updates the study process for transmission reliability analysis procedure. Effective: June 1.

3. TIMING OF DAY-AHEAD MARKET (9:30-9:45)

The committee will be asked to approve a problem statement and issue charge to review options for moving the day-ahead energy market and reliability unit commitment timelines in response to the Federal Energy Regulatory Commission’s final rule on gas schedules. PJM must make a compliance filing in response to the order by July 23. Discussions would take place at the MRC. (See PJM Considering Change to Day-Ahead Deadlines in Response to FERC Gas Schedule Order and related story, PJM, IMM Considering Changes to Virtual Trades, Day-Ahead Market.)

4. INTERIM FEE FOR VIRTUAL TRANSACTIONS (INCs/DECs and UTCs) (9:45-10:30)

Members will be asked to approve a proposal by Inertia Power to impose a temporary uplift fee of $0.07/MWh for increment offers, decrement bids and up-to-congestion bids. The proposal would expire in six months or upon FERC approval of an alternative. Transactions placed between September 2014 and the effective date of the filing would not be affected.

The proposal is in response to a Section 206 proceeding ordered by FERC to determine whether PJM is improperly treating UTCs differently from INCs and DECs. Sponsor Noha Sidhom, who announced the proposal at last month’s MRC meeting, has removed a provision limiting the fees to netted transactions. (See Cool Response to 7-Cent Fee on Virtual Transactions.)

Suzanne Herel

ISO-NE Prices Jumped 13% Last Year

By William Opalka

ISO-NE’s average real-time prices rose 13% to $63.32/MWh in 2014, the RTO’s Market Monitor reported Wednesday.

iso-ne
Natural gas generation was marginal in about 70% of hours in 2014, about equal to 2013 but down from 80% in 2012.

The 2014 Annual Markets Report said the increase was largely driven by higher fuel costs in the first quarter. Prices of natural gas, which was the marginal fuel for the RTO in 70% of the hours in 2014, rose 15% last year, to $7.99/MMBtu from $6.97/MMBtu in 2013. Electricity usage dropped 2% to 127,138 GWh.

“Overall, 2014 weather was milder compared with 2013, but the extreme cold in January, February and March and the resulting high natural gas and power prices were the main reason for 2014’s higher annual average power price,” Jeffrey McDonald, ISO-NE’s vice president of market monitoring, said in a statement. “Lower oil and natural gas prices, combined with mild summer weather that contributed to lower energy usage, and the implementation of several ISO market enhancements that helped improve both reliability and market efficiency, brought generally lower wholesale electricity prices during the rest of the year.”

The Monitor repeated a recommendation it has made since its 2010 report: that the RTO relieve virtual transactions from energy market payments — also known as real-time net commitment-period compensation (NCPC) charges — that it said is preventing virtuals from improving day-ahead market liquidity.

Last year, the RTO proposed a partial solution that would have excluded positive load deviations from real-time first contingency NCPC charges. The Monitor said the change would strengthen incentives for load-serving entities, exporters and virtual demand bidders to buy energy in the day-ahead market.

iso-ne

The proposal was unable to win stakeholder support and was not submitted to the Federal Energy Regulatory Commission. The RTO plans to start a new stakeholder process to reconsider the issue this year.

Total reliability payments, including NCPC charges, increased 10% to $173.7 million in 2014. About 62% of the payments stemmed from the need to operate more expensive generation during extreme cold weather in the first quarter.

The total value of the region’s wholesale electricity markets, including electric energy, capacity and ancillary services markets, rose about 12%, from about $8.8 billion in 2013 to about $9.9 billion in 2014. Electric energy comprised $8.4 billion of the total in 2014, up from $7.5 billion a year earlier. The cost of ancillary services jumped 50% to about $410 million.

PJM Members Committee Briefs: May 2015

ATLANTIC CITY, N.J. — The Members Committee last week gave final approval to a measure tightening rules on lost opportunity payments for generators.

Under the new rules, PJM will use the schedule that the resource is committed on for energy as the reference for lost opportunity costs unless it is self-scheduled. For self-scheduled resources, PJM will use the higher of the available cost or price curves.

In addition, combustion turbines that are scheduled in the day-ahead energy market will be prevented from receiving start-up and no-load costs when they do not run in real time. (See PJM Members Tighten Lost Opportunity Cost Rules; Tech-Specific Eligibility Retained.)

Adam Keech, PJM’s director of wholesale market operations, said the previous rules either over- or under-compensated generators.

Demand Response Verification

Members also approved Tariff and manual revisions regarding PJM’s use of sampling to measure and verify residential demand response. The new measurement method was originally endorsed by the MC in January. Thursday’s vote approved the inclusion of an additional transition year because of delays in filing the new method with the Federal Energy Regulatory Commission.

Rich Heidorn Jr.

Emergency Resources Get New Focus at MISO

By Chris O’Malley

With its reliance on demand response and behind-the-meter generation increasing amid generator retirements, MISO plans to update the way it sets prices during emergency resource offers.

The emergency pricing proposal is “one of the key reforms” that MISO is likely to make next year, Jeff Bladen, executive director of market design, told the Markets Committee of the Board of Directors on Wednesday.

miso“It’s at least plausible, and maybe even likely, that under emergency conditions when we deploy load-modifying resources, we would … depress prices,” Bladen told the committee. “The rule change that we’re pursuing is designed to ensure that the price at least doesn’t go down and may well go up based on the highest offer of economic resource at the time.”

The proposal would involve a price floor, set as the maximum of the emergency resource’s offer cost or the highest available economic offer cost of the last resource cleared prior to the initiation of the maximum generation procedure, MISO said.

More Reliance on DR, LMR

Generation resources are projected to fall with the retirement of coal-fired plants due to the Environmental Protection Agency’s Mercury and Air Toxics Standards, which took effect in April, and its proposed Clean Power Plan, aimed at reducing carbon dioxide emissions.

MISO projects 2015/2016 total generation at 122.9 GW — down nearly 1.6 GW from 2014/2015.

“What you see is a reduction of about a gigawatt-and-a-half of actual generation supply as being relied on to meet our reliability requirements. It’s effectively being replaced by behind-the-meter generation and by demand response and to a lesser degree by external resources,” Bladen told the committee.

Will They Show Up if Needed?

Because it has had ample generation supplies in the past, MISO has no recent history of deploying load-modifying resources (LMR) — and that’s a challenge of its own.

miso

Bladen told the committee that MISO “has questions about the degree to which we can actually rely on emergency and load-modifying resources,” particularly what’s available on a real-time basis. “The challenge here is we have no recent deployment history.”

To better gauge reliability, MISO staff have been running monthly LMR drills with participants. Participation rate has been increasing significantly since 2014. One problem identified has been that participants sometimes do not provide signals to MISO when their LMR or DR resources have been already deployed, leaving uncertainty as to how much relief MISO can count on.

“There’s no testing protocols currently. Even though people are required to provide availability notifications, there’s no penalty, if you like, for not providing availability notifications, although most are very diligent about doing it. So that leads to real concerns about the reliability and availability of those load-modifying resources,” Bladen said.

Todd Ramey, MISO’s head of real-time operations, said as a control room operator, the bottom line is that “I don’t have situational awareness of 2 to 3 GW of planned capacity resources” claimed by members to meet their firm requirements.

Ramey said he plans to seek development of an issues statement to address the lack of information on such resources.

Director Baljit “Bal” Dail echoed concerns, saying the discussion about the reliability of DR and LMR has been going on for a long time.

“In a market that is tightening, I think we need to have much greater clarity about what is going to show up and what isn’t,” Dail said.

Director Michael Curran underscored the urgency, saying: “Aren’t we at the ‘time-is-of-the-essence’ stage? … Time is essentially running out on us.”

‘Cascade’ Effect

Unlike PJM, most of MISO’s DR assets are administered through state programs. As a result, they would not be directly affected if the U.S. Supreme Court lets stand an appellate court ruling voiding the Federal Energy Regulatory Commission’s jurisdiction over DR in energy markets. (See MISO Ponders Large DR Role.)

But Bladen said MISO could be affected if the court’s ruling results in neighboring systems being unable to certify as much DR as they have in the past to meet their requirements.

“It might well mean that some capacity or other resources that we currently rely upon actually become that much more interested in supplying other systems,” Bladen said.

“Maybe prices go up on other systems and that further encourages exports. So the cascade event is likely the one that we would watch mostly closely,” he said.

New PJM Board Member Elected, Re-election Eligibility Changed

By Suzanne Herel

ATLANTIC CITY, N.J. – The PJM Members Committee last week elected South Carolina electrical engineer Terry Blackwell to the Board of Managers, where he will serve out the term of William Mayben, who is retiring after eight years.

pjmMayben’s term expires next year.

Blackwell, who retired in 2013 from his post as senior vice president of power delivery for Santee Cooper, was chosen from 10 candidates with expertise in transmission-dependent utilities, per PJM’s Operating Agreement.

The committee also re-elected Chairman Howard Schneider and board members Neel Foster and Sarah Rogers to new three-year terms.

Age, Term Limits

With no other candidates on the ballot, the vote lacked any drama. But board member Jean Kinsey, the non-voting chair of the Nominating Committee, followed the appointments with more surprising news: Going forward, members will be ineligible for re-election once they either turn 75 or have served five terms.

Had the new rule been in place, it would have disqualified Schneider from another term. The term limit will preclude Richard Lahey from seeking re-election when his term expires in 2016. Like Schneider, he has served on the board since its inception in 1997.

Kinsey’s term also expires next year. She joined the board in 2003.

PJM would not disclose the ages of its board members, so it’s unclear who might be affected by that limit.

The Nominating Committee was comprised of eight members, three from the Board of Managers. In addition to Kinsey, Ake Almgren and Susan Riley took part. Participating PJM members and the sectors they represent were: Pati Esposito (Other Suppliers), Ken Foladare (Generation Owners), Lisa McAlister (Electric Distributors), Jackie Roberts (End Use Customers) and Hertzel Shamash (Transmission Owners).

10 Candidates

The committee hired executive search firm Russell Reynolds, which identified 10 candidates, three of whom were interviewed.

Blackwell retired in 2013 after 35 years with Santee Cooper, the last four and a half as senior vice president of power delivery. He is a senior consulting engineer with McCall-Thomas Engineering, in Orangeburg, S.C. He also is a former board member and chairman of the Southeastern Electric Reliability Corp.

“He is regarded not only for his technical acumen but is widely praised in the industry for his character and collaborative working approach, both as a representative of public power, and with other industry and regulatory interests focused on the challenges of power system reliability,” outgoing CEO Terry Boston said in a letter to PJM members announcing the committee’s choice.

The board also includes Boston, who will cede his seat to incoming CEO Andy Ott, and Charles Robinson, who did not attend the Annual Meeting.

Capacity Performance Tops Consumer Advocates’ Meeting with PJM Board

By Suzanne Herel

ATLANTIC CITY, N.J. — Consumer environmental advocates told the PJM Board of Managers last week that the Capacity Performance proposal could saddle ratepayers with excessive costs because of its treatment of renewable energy. They made their case during their annual meeting with the board last week, at which they also delivered a wish list on issues ranging from cost allocation to load forecasts.

consumer advocates
Incoming PJM CEO Andy Ott, third from left, listens as consumer advocates discuss their concerns with RTO officials. © RTO Insider

Costs of Capacity Performance

Mike Jacobs, of the Union of Concerned Scientists, said wind and solar resources will be unable to qualify as Capacity Performance resources due to their intermittent nature.

consumer advocates
Mike Jacobs, UCS

“There’s a real possibility that capacity needs will be overstated, misallocating capital and overcharging users,” he said, explaining that while the renewable resources won’t be in the capacity auction, they will be added as a result of state renewable portfolio standards. Thus, he said, “consumers will pay twice” for that capacity.

The consumer advocates said they doubt the need for the “vast changes” in the proposal, which they said will be “a dominant focus” of their cost concerns. The advocates asked the board to limit future changes to permit “a period of stability in the capacity markets.”

“I think many of us think of our grandmothers or others in our lives who depend on energy and for whom price increases that seem maybe to us the cost of an extra latte at Starbucks really do make a difference,” said Robert Mork, deputy consumer counselor for the Indiana Office of Utility Consumer Counselor.

The Federal Energy Regulatory Commission is expected to decide by June 9 on the proposal.

Demand Response

The consumer advocates said they were “heartened, but not over-optimistic” by the Supreme Court’s decision to reconsider the D.C. Circuit Court of Appeals’ ruling vacating FERC’s authority over demand response in wholesale energy markets. The court said DR is a retail product and thus subject to state, not federal, jurisdiction. (See Supreme Court Agrees to Hear Demand Response Appeal.)

“Should the Supreme Court uphold the Circuit Court order, we urge the board to limit PJM’s response to the energy market until FERC rules on any further implications” regarding regulation of DR in capacity markets, the advocates said.

Artificial Island Cost Allocation

The cost allocation issue was sparked by PJM planners’ recommendation of a stability fix for New Jersey’s Artificial Island nuclear complex.

While one transmission solution considered by PJM would have spread costs among two dozen transmission zones and merchants, the proposal selected may be assigned entirely to the Delmarva Power & Light zone in Delaware. (See Delaware Unhappy with Artificial Island Cost Allocation.)

“The potential allocation of all costs to a single zone suggests, to us, that cost allocation rules should be revisited,” the consumer advocates said in their presentation.

Clean Power Plan

The environmentalists focused largely on the Environmental Protection Agency’s Clean Power Plan, which the agency is expected to finalize this summer.

Allison Clements, director of the Sustainable FERC Project, urged a multi-state compliance scheme, which PJM analyses already have pegged as the most affordable approach to the carbon reduction effort. (See PJM: Regional Approach the Cheapest Way to Comply with EPA Carbon Rule.)

Clements said that while most RTOs’ studies of the plan have not met minimum modeling requirements, PJM’s have been good.

“There’s not a doubt in my mind that a multi-state plan will save millions of dollars,” said outgoing CEO Terry Boston. But, he said, “In any multi-state plan, there will be winners and losers. How can we collectively work so there can be economic benefit for those states that lose? How can we work together to show these benefits are real and can be traded?

“This is something for you as a group to be thinking about and working with your states on,” he said.

Jackie Roberts, director of the West Virginia Public Service Commission’s consumer advocate division, said the best way to persuade political leaders opposed to the plan to join in regional compliance is to “show them the economics of it. That’s what’s going to be persuasive to the governors and their environmental departments.”

consumer advocates
Richard Lahey, PJM Board

Board member Richard Lahey asked the environmentalists about their opinion on nuclear power’s role in meeting compliance. Nuclear power provided more than one-third of PJM’s generation in 2014.

“If we lose that, we’re really worried about the stability of the grid and there would be a huge increase in CO2. It would be irreversible,” Lahey said.

Clements said there is “no consensus” among environmentalists on the subject. As a result, she said, Sustainable FERC Project has focused on “cheap, clean and quick” resources such as energy efficiency and renewables.

Clements lauded adjustments PJM is making in its load forecasting to reflect the impact of energy efficiency. She urged planners to broaden their efforts to capture the impacts of distributed generation and price-responsive demand. “Traditional GDP-related variables no longer correlate well with load growth,” she said.

Pledge to Seek Consensus

While they mostly made requests, the consumer advocates also pledged to do their part to help reach consensus in the stakeholder process — a response to requests by Boston and Board Chairman Howard Schneider.

consumer advocates
Ruth Ann Price, Delaware Division of the Consumer Advocate

As an example, said Ruth Ann Price, deputy Delaware Public Advocate, the group is working with Calpine and other generators on an intraday pricing initiative. (See Bid for Generator Price Flexibility Draws Debate Over 10% Adder.)

Price said they are trying to identify issues early in the process to increase the odds of compromise.

“Contentious litigation is time-consuming, expensive … and doesn’t represent the culture and values that we all want to support,” she said.