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November 13, 2024

Manual Changes Approved by Planning Committee on June 6, 2013

The Planning Committee Thursday approved changes to Manual 19: Load Forecasting and Analysis. The changes go next to the Markets and Reliability Committee.

Reason for changes: Integration of East Kentucky Power Cooperative (EKPC), addition of annual demand resources; and need to ensure accuracy of load shed programs.

Impact:

  • Adds EKPC to load forecast model;
  • Revises assumption for winter load management;
  • Makes minor typo fixes and clarifications for NERC audits;
  • Changes demand resources available in winter months due to addition of annual DR product; and
  • Codifies guidelines for switch operability studies for load management programs. The guidelines are designed to ensure the accuracy of load shed estimates for participants in Direct Load Control programs. The study must be designed for a minimum 90% confidence level and based on a randomly selected sample from the entire population of participating customers. No customers can be excluded.

PJM contact: John Reynolds

MIC Seeks Better Way to Draw Capacity Supply Curve

The Market Implementation Committee will consider modifying the algorithm used for publishing supply curves resulting from the annual capacity market auction.

MIC Wednesday approved a problem statement by Jason Barker of Exelon to seek improvements to the supply curve currently produced by the Market Monitor, which masks individual price-quantity offers. The practice is a compromise resulting from a 2010 Federal Energy Regulatory Commission order (ER09-1063-003) that sought to balance transparency against disclosure of commercially sensitive data.

Barker said the current curves are not accurate enough for any Locational Deliverability Area to be useful in analysis.

The FERC order resulted from a dispute over PJM’s proposal to publish price-quantity pairs after the 2010 Base Residual Auction. Constellation Energy and the monitor said that, due to the concentration of generation ownership in the SWMAAC LDA, the data could be used to reconstruct market participants’ offers.

Barker presented examples of two different algorithms that he said would improve the current methodology: a six variable polynomial and a four-period moving average. The current method, based on a single variable equation, produces a smoothed curve that passes through the intersection of the actual supply and demand curves.

Barker said an improved curve would provide “a better indication of slope inflections” that would help market participants analyze supply and regulators ensure auction results are just and reasonable.

Steve Lieberman, representing Old Dominion Electric Cooperative, supported the change. “It’s obvious almost any formula would be more accurate” than the current one, he said.

A stakeholder representing a retail marketer pushed for a one-month delay before a vote on the problem statement, saying he wanted to hear whether the monitor would oppose the change.

Marji Phillips, of Hess, grew impatient with the request for a delay on the vote. “This isn’t a complicated issue,” she said. “I can’t tell you how counterproductive and stupid [the discussion] looks.”

Jeffrey Mayes, general counsel of Monitoring Analytics, told the committee the monitor wouldn’t oppose changes to the formula as long they could not be “reverse engineered” to reveal actual offers. Yesterday, however, he told PJM Insider that Market Monitor Joseph Bowring is “convinced that [Exelon’s suggested  alternatives] do reveal the offer data that we’re concerned about.”

The statement was approved by acclimation, with 16 abstentions. MIC will consider the Issue Charge at its next meeting. Barker said the work should be completed by December to enable analysis of the 2016/17 supply curves under the revised algorithm before the 2017/18 auction. Any change will require FERC approval.

PJM: We’ll Sue

Settlement Near?

By Rich Heidorn Jr.

We started publishing PJM Insider a few months ago to provide comprehensive and objective news coverage and analysis of the PJM Interconnection. In this article, we won’t pretend to be objective, because this involves us – and you.

Those of you who have attended or listened in to PJM meetings in the last few months have gotten used to me introducing myself with the statement: “PJM Insider is neither associated with, nor endorsed by, PJM Interconnection, LLC.”

A number of you whom I’ve gotten to know personally have shaken your head in disbelief when I told you that — despite the ubiquitous disclaimers on our website and newsletter — PJM has been threatening since February to sue us over our name.

On Thursday, PJM sent a draft of that long-threatened suit to our lawyer. Central to PJM’s claim is that we are confusing you into thinking we’re connected with PJM. PJM also accuses us of “unfair competition.”PJM-draft-lawsuit-header-only

Since receiving the suit, our lawyer has spent hours on the phone with PJM’s counsel in an attempt to settle this matter without litigation.

As we will explain later, we feel very strongly that the use of “PJM” in our title is protected by both the fair use doctrine and the news reporting/news commentary privilege. We are confident that we would win in court.

But as a small, very new publication, we have to pick our fights. We have agreed to pursue settlement discussions to avoid the distraction and cost of litigation and keep our focus on providing PJM’s stakeholders with the best quality journalism and analysis.

This is a service PJM deserves – and more importantly – needs. Hundreds of you tell us every week that you agree, by opening our emails and visiting our website.

The final details of this settlement should be worked out over the next couple days. The outlines are the deal are that we will agree to transition to a new title and new URL using our corporate name, RTO Insider.

So, sometime soon, you may see “RTO Insider/PJM.” Same intensive coverage, less contentious name.

We’ll provide more details in a couple of days. The less said now — in the middle of negotiations — the better.

In the meantime, know that we remain: “Your Eyes and Ears at the PJM Interconnection.”

Alternative Wind Capacity Calculations Yield Murky Results

Proposals to eliminate the impact of curtailments on wind generators’ capacity calculations create many losers as well as winners, according to data presented to the Planning Committee Thursday.

Two proposals are being considered under a problem statement approved in April to protect intermittent generators from being assigned artificially depressed capacity values as a result of curtailments directed by PJM.

Wind-generator-curtailments-2012

 

Under current policy, when wind generators are curtailed by PJM for any portion of a peak summer hour, the hour is excluded from the generator’s capacity credit calculation.

PJM staff conducted an analysis of the two alternative calculations using data for summer 2012, when 33 of 50 wind generators had at least one curtailment.

Alternative 1

Impact-of-Alt.-1-on-Curtailed-UnitsAlternative 1 removed from the calculations only the five-minute periods in which a curtailment occurred rather than the full hour, as in current practice.

It increased capacity factors for 21 of the 33 units that experienced curtailments (64%).  Changes ranged from an increase of 2.6 percentage points to reductions of almost 2 points with a median increase of 0.2 points.

The biggest increases in capacity factors went to units curtailed most frequently — a 2 percentage point boost for most units with more than 150 curtailed five-minute periods.

Alternative 2

Alternative 2 reduced capacity factors for 21 of 33 curtailed generators. It estimates what the generator’s output would have been during curtailment by interpolating data between the five-minute periods before and after the interruption.Impact-of-Alt.-2-on-Curtailed-Units

Alternative 2 showed a more normal distribution of impacts, with little correlation to the number of curtailment periods. It reduced capacity factors by a median of 0.2 percentage points, with some units losing almost 2 points while others increased by 2 points.

No Robust Solution

Steve Herling, PJM vice president of planning, said PJM limited the analysis to 2012 because data from prior years was not as reliable or complete.

“With only one year of data it’s going to be very difficult to come up with a solution that’s really robust,” Herling said. “That doesn’t mean we shouldn’t try to do something.”

The committee will be asked at its next meeting to decide whether to choose one of the alternatives or to leave the methodology unchanged.

PJM’s current procedure uses hourly integrated metered data. The two alternatives would use five-minute data from PJM’s state estimator. Because the hourly integrated data is more accurate, PJM plans to continue to use that data for the units with no curtailments, said PJM’s Tom Falin.

See “MRC Action: Calculating Capacity Values for Intermittent Resources.”

Gas Dispatch Reduces Congestion: Market Efficiency Study

An increase in the dispatch of gas-fired units in east PJM reduced west to east congestion in PJM’s 2013 market efficiency analysis, officials told the Transmission Expansion Advisory Committee Thursday.

“Fuel prices were the main driver” in the analysis, said PJM’s Tim Horger. Otherwise, Horger said, “results were very similar to” the 2012 analysis.

The analysis looked at study years 2014 and 2018 to determine whether projects in the Regional Transmission Expansion Plan should be accelerated or modified, and 2017, 2020 and 2023 to consider the addition of new projects to the RTEP.

2013-Market-Efficiency-congestion-costsThe study assumed:

  • Coal prices increase from $2.60/MMBtu in 2013 to $3.75 in 2023, a 4.4% annual increase.
  • Natural gas prices increase from $3.68 to $6.50/MMBtu, a 3.1% annual increase.
  • Peak demand increases 1.4% per year, from 154,712 MW in 2013 to 176,548 in 2023.

PJM will post case files for all study years. Accessing the files requires authorization to access Critical Energy Infrastructure Information (CEII) and a license from Ventyx for powerbase data.

A PJM Model for Natural Gas?

NEWARK, NJ — Would the PJM model work for the natural gas industry? Charles River Associates’ Robert Stoddard thinks it’s worth a try.

Stoddard told the Energy Bar Association’s Northeast Chapter Wednesday that a Regional Pipeline Organization, or RPO, could help address the pipeline capacity shortage that has complicated the growing interdependence between the natural gas and electric industries.

He said the current $1.65/MMBtu basis spread between Henry Hub and the Algonquin citygates is evidence of the need for an additional interstate pipeline serving the Northeast. But pipeline operators cannot build without firm supply contracts – which few gas-fired generators have been willing to sign.

“Right now we have no one who is responsible for thinking about a plan” for pipeline expansion, he said. “We are piggybacking on pipelines that were built for [local distribution companies] … How do we expect that to work?”

While the other speakers on the panel agreed on the need for more pipeline capacity, none embraced Stoddard’s RPO proposal.

Richard Kruse, who heads regulatory affairs for interstate pipeline operator Spectra Energy Transmission, said his company has been serving the industry for 50 years. “And we did it,” he said, emphasizing the point, “without an RPO.”

RPO Not Suitable

Kruse said the RPO concept is not suited to the nature of the natural gas industry and would eliminate competition among pipelines for expansion opportunities.

“We’re not regional pipelines, we’re linear pipelines. You’re talking about breaking up companies and remolding them,” he said. Spectra owns three pipelines that are more than 1,000 miles long, including Texas Eastern Transmission, which spans 9,200 miles from the Gulf Coast to Northeast.

John P. Rudiak, senior director of energy supply for local distribution companies Connecticut Natural Gas Corp. and Southern Connecticut Gas Co., also was cool to the idea.

“An RPO might have been credible a year ago. That’s not the case now,” Rudiak said, explaining that the gas industry has been increasingly talking to ISO New England, which has more than 500 wholesale market participants and more than two dozen stakeholder committees and working groups. “[The gas industry is] not very impressed with the workings of the ISO. It is a process that’s very cumbersome to say the least.”

Market Disconnects

Stoddard said the varying tariff rates in the pipeline industry distorts least-cost dispatch in electricity. “Instead of dispatching the unit with the lowest carbon footprint we’re dispatching those that happen to have the cheapest gas,” he said.

Stoddard said gas-fired generators are reluctant to commit to firm contracts because it is very difficult for individual generators to forecast how often they will be dispatched, and thus how much gas they will burn. Because so many gas-fired generators have similar specifications and cost profiles, he said, “which one gets committed is sort of like drawing a lotto card.”

Communication Gaps Not the Issue

What the speakers did agree on was that the challenge is one of infrastructure and not one of a lack of communication between the gas and electric industries.

Kruse said the two industries have been increasing communication in the Northeast since the 2004 Boston “Cold Snap,” when the coldest January in 116 years pushed the electric and natural gas systems to record demand. “Never have so many talked about so much and accomplished so little,” he said, adapting a quote from Winston Churchill.

Kruse said data requests sent to ISOs by the Federal Energy Regulatory Commission last week “could have [been] written … a year ago, two years ago, in 2004.”

Matthew J. Picardi, vice president of regulatory affairs for Shell Energy N.A.’s East region, said there’s no need to move to a common gas-electric trading day, as some have urged, though he said there could be benefits to moving up the gas day — which starts at 9 a.m. Central time — by an hour. The real issue, he said, is “power markets must support costs for more gas infrastructure.”

Too Much Information?

Kruse expressed concern that the gas industry could be providing too much information to grid operators.

“The ISO is a market player that actually decides who uses gas,” he said. “How much communication with ISOs [is permissible] before it becomes an undue preference to the electric industry versus our other customers?”

To Build or Not?

While all of the speakers on the panel called for more pipeline construction, FERC Commissioner John R. Norris, in separate remarks to the EBA, called for a long-term view.

He cited a projection that cutting CO2 emissions 80% by 2050 — a target the U.S. agreed to at the 2009 G8 summit — will require eliminating gas as a baseload fuel. Gas-fired generation would be limited to load following in support of variable generation.

Such a shift would conflict with the economics of the pipeline industry, which expects to recover its investment in new pipeline capacity over 30 years or more. “Is [a new pipeline] smart long-term energy planning?” he asked.

PJM: We’ll Be Cautious on Transmission Project Disclosures

PJM “will err on the side of caution” in disclosing details from transmission developers’ project proposals, RTO officials told the Planning Committee Thursday.

On April 29, PJM announced opened its first “proposal window” under the Fed­eral Energy Reg­u­la­tory Commission’s Order 1000, which opens transmission projects to non-utility trans­mis­sion devel­op­ers. PJM will accept pro­pos­als through June 28 to cor­rect sta­bil­ity issues on Arti­fi­cial Island in Han­cocks Bridge, N.J., the site of the Salem and Hope Creek nuclear plants.

Steve Herling, PJM vice president of planning, said the RTO will release “no brainer information” on proposals submitted in response to the Artificial Island needs and future proposal windows.

Such information would include “a line from A to B, impedance modeling, so people can analyze [the proposals],” Herling said. “We won’t put out right of way information. You’d get the public all stirred up that `we’re looking at your property.’”

Prequalification

Order 1000 elim­i­nated incum­bent util­i­ties’ Right of First Refusal on con­struc­tion and oper­a­tion of new trans­mis­sion lines, open­ing the busi­ness to com­pe­ti­tion from inde­pen­dent trans­mis­sion devel­op­ers. Incumbents will retain the right to construct “upgrades” to their existing facilities.

PJM has created a two-step process for complying with Order 1000. First, potential transmission developers must be prequalified based on their ability to construct and maintain a generic transmission project.

Those prequalified will be eligible to submit solution packages in response to proposal windows like that for Artificial Island.

PJM officials said Thursday that seven developers have submitted prequalification packages with more applications expected shortly.

Herling said the application packages will be posted publicly after PJM determines which ones are prequalified. “There has to be some due process to challenge the decisions we’ve made,” he said.

Constructability Template

PJM has created a template to evaluate responses to its proposal windows. The RTO plans to hire independent consultants to validate developers’ cost estimates and identify potential regulatory risks, such as the likelihood of obtaining siting for rights of way.

“If you have half the right of way in hand, that certainly will have an impact on cost and regulatory risk and would probably affect construction time,” Herling said. “To give you credit, we would have to disclose some information. We don’t have to talk about individual pieces of property you have.

“If it becomes obvious that we’re relying heavily on one piece of information we’re going to have to make it public — and you might still not get chosen,” he continued. “… We’ll have to make sure it’s transparent and above board to defend ourselves against challenges.”

Manual Changes Approved by the Market Implementation Committee on June 5, 2013

The Market Implementation Committee Wednesday approved changes to Manual 11 affecting regulation rules, hydropower generators, station manning and shortage pricing. The changes go next to the Markets and Reliability Committee.

Reason for changes: Clarifications, error corrections and changes to conform with other manuals.

Impact:

The changes:

  • Clarify and add conforming language for regulation rules:
    • Resources cannot clear for both RegA and RegD within an operating hour (Section 3.2.9)
    • Changes language to conform with M12: Regulation resources must return to their regulation range within 10 minutes of the end of a synchronized reserve event (Section 4.2.12). The current language calls for a return within two minutes.
  • Clarify hydropower units’ opportunity cost when providing synchronized reserve:
    • Hydro units providing Tier 2 synchronized reserve receive lost opportunity cost payments only when they are held to condense mode rather than off-line. (Section 4.2.7)
  • Corrects and clarifies Attachment C regarding cost offers and station manning:
    • Removes language stating that a resource can submit only five cost offers for energy. The actual limit is “in the 60s,” said Rus Ogborn, of PJM.
    • Clarifies the compensation rules that apply when PJM requests resources to be manned in order to start units more quickly. Units required to provide staffing will be compensated even if the resource is not called on because system conditions change.
  • Clarifies and cleans up revisions for Shortage Pricing rules. Changes were made to clarify existing rules and remove errors in the current text.

PJM contact:  Rus Ogborn

Industrials Call for Transparency in Transmission Owner Calculations

Two-thirds of PJM’s transmission owners have failed to file FERC-approved tariffs disclosing the methodology they use to calculate customer rates, PJM industrial customers told the Markets and Reliability Committee Thursday.

“There’s a vacuum in the tariff,” said Robert Weishaar, an attorney with McNees Wallace & Nurick LLC who represents several industrial energy users. “There’s a lack of transparency and a lack of accountability… Utilities sometimes change methodologies without notice.”

Weishaar will ask MRC June 27 to approve a problem statement that could result in requirements that transmission owners make tariff filings disclosing their calculation of total hourly energy obligations, peak load contributions, and network service peak loads. The calculations are used to allocate energy, capacity, and transmission cost responsibility among load serving entities.

Weishaar said the disclosures are required by the Federal Energy Regulatory Commission’s “rule of reason” as provisions that affect rates, terms, and conditions.

Weishaar’s proposal is intended to require Baltimore Gas & Electric, PECO Energy, PPL Electric Utilities, Dominion, Dayton, PEPCO, AEP, Duquesne Light Company, Rockland Electric, and Duke to file Attachments M-1 or M-2 to the PJM OATT disclosing their methodologies.

Weishaar said FirstEnergy, Commonwealth Edison, Public Service Electric & Gas, Atlantic City Electric and Delmarva Power & Light have already filed such disclosures.

Weishaar said the descriptions need to be detailed enough to allow LSEs to verify the accuracy of the calculations. Attachments “that merely reference methodologies contained in manuals posted on the transmission owner’s website do not adequately address the problem,” the problem statement says. “Because the necessary level of detail is not included in a FERC tariff, transmission owners may change methodologies, or inconsistently apply methodologies, with little recourse to LSEs and their customers.”

The problem statement also calls for PJM to establish default methodologies that would apply for zones without tariff attachments. It seeks a FERC filing within three months after assignment by the MRC.

Manual Changes Approved on May 30 at the PJM MRC

The Markets and Reliability Committee gave final approvals to the following manual revisions at their meeting this past Thursday.

  • Electronic Notifications for Curtailment Service Providers: Changes to Man­u­als 1 and 18 will imple­ment an auto­mated process that will allow Cur­tail­ment Service Providers to pro­vide oper­a­tional data to — and receive dis­patch instruc­tions from — PJM. The new Load Response System (eLRS) process replaces the current manual methods, which rely on email and spreadsheets.

See “Manual Changes to Implement Electronic Notification System.”

  • Resid­ual Zone Pric­ing: Resid­ual Zone Pric­ing will replace phys­i­cal zone LMPs for real-time load effec­tive June 1, 2015. A Resid­ual Zone is an aggre­gate of all load buses in the phys­i­cal zone, exclud­ing load priced at nodal locations. The change was endorsed by the Mem­bers Com­mit­tee in Feb­ru­ary 2012 and approved by FERC in Docket ER13-347.

See “Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market.”

  • East Ken­tucky Power Coop­er­a­tive: PJM needs to add the East Ken­tucky Power Coop­er­ative zone into PJM mar­kets man­u­als to accommodate the coop’s inte­gra­tion into PJM, effec­tive June 1.

See “Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market.”

  • NERC Reliability Standards: PJM needs to amend M-36: System Restoration to reflect NERC Standards EOP-005-2 (System Restoration Plans) and EOP-006-2 (Reliability Coordination – System Restoration).  Updates for consistency with other RTOs; updates underfrequency load shed tables; incorporates recommendations from RFC/SERC audit, and adds specific references to transmission operator restoration plans.
  • Manual 03A:  Energy Management System (EMS) Model Updates and Quality Assurance: The changes include numerous edits for updates and clarity.

See “Manual 03: Transmission Operations.”

  • Regulation Market Cost-Based Offers:  New rules imple­mented in Octo­ber require reg­u­la­tion offers to include capa­bil­ity (cost, in $/MWh to reserve a resource for reg­u­la­tion) and per­for­mance (costs of track­ing the reg­u­la­tion sig­nal in miles/MW).  Pre­vi­ous rules, as defined in Man­ual 15, did not include per­for­mance costs.

See “Manual, Tariff Changes: Residual Zones, EKPC, Loss of Internet, Regulation Market.”

  • Manual 35: Definitions and Acronyms: Adds language to Economic Maximum and Economic Minimum definitions; changed Operations Analysis Working Group to Operations Assessment Working Group; Replaced TTV4TF (TO/TOP Version 4 Task Force) with TTMS (TO/TOP Matrix Subcommittee).
  • NERC standard PRC-023-2: Updates to Manual 14B: PJM Region Transmission Planning Process are required to implement standard PRC-023-2 (Transmission Relay Loadability). PJM annually develops a transmission facility list to comply with NERC criteria.
  • Manual 03: Transmission Operations: Semi-annual update to incorporate procedural changes.