TEMPE, Ariz. — Stakeholders interested in participating in SPP’s Markets+ service offering in the Western Interconnection last week approved much of the draft tariff language they’ve developed together in recent months.
That tickles SPP attorney Chris Nolen, whose frequent comments about building “the best tariff ever” are being repeated by SPP staff and potential western stakeholders.
“We’ve moved, in my opinion, more efficiently, faster, better than I thought we would when we had our kickoff meeting,” he said during a break in the Nov. 7-8 Markets+ Participant Executive Committee (MPEC) meeting. “It’s been super impressive how all the market participants, everybody involved at all the stakeholder groups picked up really quickly on how it works, how it runs, how you make comments, how you get changes you want to see in the tariff language. I think we’re in an excellent spot.”
MPEC members endorsed chunks of tariff language that define how the day-ahead Markets+ will handle market transmission use, congestion management, transmission capacity obligations, market manipulation and confidentiality. The Interim Markets+ Independent Panel (IMIP), composed of three SPP directors, added its approval as well.
However, the Markets+ Greenhouse Gas Task Force was given up to eight weeks to approve draft language incorporating GHG emissions-related information in the market’s reporting, price formation, commitment and dispatch. The group already has a conceptual framework.
The Pacific Northwest’s only cap-and-trade program, Washington state’s cap-and-invest initiative, has a Nov. 1, 2024, compliance deadline. By that time, affected entities need to have enough allowances to cover 30% of their 2023 emissions. (See “GHG Issue: ‘Emissions Leakage’,” Markets+ Stakeholders Begin Tariff’s Development.)
A proposed option of making a supplemental filing at FERC once the cap-and-invest program’s rules become clear failed to garner enough support. Washington’s Department of Ecology, which is overseeing the program, has an ongoing rulemaking to be completed next summer.
Task force chair Mary Wiencke, with The Public Generating Pool, said she expects the rulemaking to be delayed by Ecology’s concerns over Markets+’s final market design.
“There’s a real cart-before-the-horse and a real chicken-and-egg issue here,” Wiencke said. “Somebody has to go first, and so then the rules in the market design have to be jointly sort of put together. … We need a market design to have rules also. This process is going to be iterative, no matter what.”
“When you do that four to six weeks, or four to eight weeks, the pressure is really on all of us because we know that there’s a pretty significant consequence if we don’t get there,” PowerEx’s Mark Holman said. “We’re either [filing a supplemental] or we’re into a tariff delay that affects everything in this initiative. I like that pressure being on. I think it’s worked well. We will have different resources that roll their sleeves up and not sacrifice the quality of the solution, but actually get it done.”
The GHG delay could throw a kink in SPP’s plans to have the tariff complete in December and take it to the RTO’s Board of Directors in February. SPP hopes to receive IMIP approval Dec. 14 before taking it to the board; the tariff would be filed in the first quarter next year, assuming final approval.
The task force will report on its progress during MPEC’s Dec. 6-7 virtual meeting, which once was a one-day call.
“We want to have the tariff and all the policy items done by December,” said Carrie Simpson, SPP’s director of seams and western services development. “However, to the extent that we’ve got some stuff that’s still hanging around or there’s a policy item that needs extra time, I don’t know that January’s a [hard deadline].”
No need to worry about the additional time afforded to the GHG task force, Nolen said.
“It’s just complex, so it’s taken a little bit when you plug it in to the broader market,” he said. “It’s new. We’ve never had to plug one in yet.”
Nolen told MPEC if SPP receives the GHG tariff language in mid-January, staff will need only a week to “holistically consider” the tariff and to file at FERC.
“If we tried to wait and amend the filing after the fact, that brings up some of the complications with pushing this date,” he said. “When the pens go down, we need eight weeks internally to run through that tariff and be sure that we wired everything out to the baseline tariff and everything works.”
“The degree of collaboration and consensus that’s been required to develop this volume of tariff language this quickly is tremendously encouraging,” Antoine Lucas, SPP’s vice president of markets, said after the meeting. “SPP and the Markets+ participants are striking a remarkable balance between speed and meaningful consideration in developing a market that works for all stakeholders.”
FERC’s approval of the Markets+ design would begin the market’s second phase of development. At that point, SPP would acquire the necessary software and hardware, participating entities would fully commit to funding the market and they would be integrated into the system.
Go-live is targeted for October 2026.
WRAP, RTO West Advance
SPP also celebrated recent “significant” progress with the other prongs of its western expansion. It said an important element of the Western Power Pool’s Western Resource Adequacy Program (WRAP) that it operates became operational Nov. 1, and the grid operator formally kicked off its RTO West development in Denver.
WPP says the WRAP is the first regional reliability planning and compliance program in the history of the West. Its operations program produces updated forecasts each season to help determine whether participants will have sufficient resources and enables those with a deficit to secure additional resources.
The RTO said the program will remain non-binding for an undefined time.
“SPP is grateful for our partnership with Western Power Pool and the opportunity to help assure resource adequacy for their member utilities,” Casey Cathey, SPP’s senior director of grid asset utilization, said in a statement.
On Nov. 9 in Denver, SPP hosted utilities that have committed to joining as members of its RTO in the Western Interconnection. The grid operator presented its plan to coordinate the utilities’ integration into SPP’s planning, reliability coordination, market and other services before operations are targeted to begin in April 2026. (See WAPA, Basin Electric Commit to SPP’s RTO West.)
SPP’s senior vice president of operations Bruce Rew, who leads the RTO expansion program, said the kickoff was a result of years of negotiations and planning.
“We’re eagerly looking forward to the day that these plans come to fruition and we have the opportunity to bolster grid reliability, bring efficiency to planning processes and leverage the full potential of a single interregional market across two interconnections,” Rew said.
Much of the RTO West’s development will be handled through SPP’s normal stakeholder process, staff said.
A key difference between the draft National Transmission Needs Study the Department of Energy released in February and the final version issued Oct. 30 is a new section in the introduction spelling out what the goals of the report are and, equally important, what they are not.
“The objective is to identify pressing transmission needs across the nation,” said Jesse Schneider, a policy adviser in DOE’s Grid Deployment Office (GDO), which authored the report. “However, the study does not prescribe any specific transmission solutions to meet those needs.”
Speaking during a recent webinar on the report, Schneider further stressed “the study findings are intended to inform department transmission priorities, including implementation of funding programs, technical assistance or broader transmission planning programs.” The report is not intended “to supplant or presuppose any existing transmission planning activities,” he said.
Similarly, while the study does break down transmission needs by region, that analysis will be used to “inform” but not designate any National Interest Electric Transmission Corridors (NIETCs) ― areas where transmission constraints and congestion could be improved with federal funding and accelerated permitting. (See What Are National Interest Transmission Corridors and Why Do We Need Them?)
DOE issued a request for information on the process for designating NIETCs in May and, as with the Needs Study draft, received a range of comments. In her opening remarks at the Nov. 8 webinar, GDO Director Maria Robinson said further guidance on NIETC designation would be released by the end of the year. (See States, RTOs Caution DOE on Transmission Corridors.)
Separate from NIETCs, DOE sees the Needs Study as a resource that can be used to encourage entities “to revise their planning processes to incorporate these findings, including consideration of a wider range of transmission benefits [and] portfolios of transmission project evaluation, rather than individual project evaluation,” Schneider said.
Broader planning perspectives also might include “scenario-based planning with longer time horizons to incorporate alternative transmission solutions including grid-enhancing technologies, as well as weather data [that] better reflect future extremes,” he said.
The need to explain the study’s goals and how it should and shouldn’t be used was raised by a number of the 58 groups and individuals who submitted a total of 330 comments on the draft Needs Study. The comments were summarized, with the department’s responses, in an 80-page appendix to the final.
The range of comments and the resulting revisions made to the final study reflect the complexities of grid planning as the U.S. generation mix moves toward cleaner, renewable resources.
“I think it does send a clear message,” said Rob Gramlich, president of industry consultant Grid Strategies. “It’s a well-done and thorough report citing many dozens of studies. So, I think, as a pure piece of analysis and information, it makes a very strong case. And it is from the Department of Energy, with the authority that entails … and is supported by all the national labs, so that gives it a lot more credibility than just a report.”
The study’s topline findings were no surprise, as Energy Secretary Jennifer Granholm said in a press call preceding the release. “We need to seriously build out transmission in order to improve reliability and resilience, and of course, to lower energy costs and relieve congestion on the grid.”
The study also finds “that of all the different configurations of transmission deployment, interregional transmission results in the largest benefits,” Schneider added during the Nov. 8 webinar, with the caveat that “transmission needs will shift over time.”
The Comments
The report’s broad and general approach — and the department’s insistence on not providing solutions — left some commenters dissatisfied. Utilities, RTOs and transmission developers all argued the report omitted projects and circumstances specific to their transmission planning and operations.
New York Transmission Owners (NYTO), a utility stakeholder group in NYISO, said the report should include four of its latest projects, which are aimed at alleviating price differentials between New York City and upstate areas, an issue raised in the draft.
PJM staunchly defended its performance during the winter storm of February 2021, commonly referred to as Winter Storm Uri, noting it provided “unprecedented amounts of power” to neighboring regions and that any limits in interregional transfers were due to “constraints in neighboring systems.”
ERCOT, on the other hand, urged DOE to treat the effects of Uri as outliers, asserting the report’s call for more interregional transmission to connect Texas to surrounding areas is overstated, given system upgrades it has undertaken since the storm.
DOE’s decision to base the report on existing studies, rather than fresh research ― and the resulting underlying assumptions ― was another flashpoint. While the draft referenced more than 50 reports, DOE was deluged with recommendations for other studies to be included, resulting in the final version reviewing and citing more than 100 reports.
Given the study’s strong focus on interregional transmission, the National Renewable Energy Laboratory’s Interconnections Seam Study ― which looked at the benefits of interregional connections ― was one of the more surprising omissions from the draft, but it was included in the final. Other additions include MISO’s Long-Range Transmission Planning Process and CAISO’s 2022-2023 Transmission Plan.
A lack of up-to-date information on transmission needs on tribal lands was another gap in the draft, according to comments from the Blue Lake Rancheria Tribe, in Northern California. In this case, DOE tapped a still-unpublished survey on tribal access to reliable electricity, which found an estimated 54,000 Native Americans, including Alaska Natives, live without electricity, the majority of them in the Navajo and Hopi nations.
Of those surveyed, 23% do not have access to a centralized power grid, and 65% said existing grid infrastructure could be extended to tribal lands, the report said in a new section on tribal transmission needs.
Multiple commenters also took issue with DOE’s base case for anticipating and modeling future transmission needs, predicting high levels of renewable energy coming onto the grid, but only moderate load growth. Consolidated Edison pointed to the potential effect on demand spurred by New York’s Climate Leadership and Community Protection Act as an example of ambitious state legislation that could drive load growth.
The law calls for New York to cut its greenhouse gas emissions 85% by 2050, with an interim goal of a 40% reduction by 2030.
Advocacy nonprofits similarly called for DOE to factor in the effect on renewable energy and load growth of the Inflation Reduction Act’s clean energy incentives and EPA’s vehicle emission standards, which are expected to accelerate adoption of electric vehicles.
The Edison Electric Institute (EEI) and Public Service Enterprise Group (PSEG) faulted DOE for not taking into account FERC’s proposed rules on transmission planning and cost allocation. According to the Needs Study, EEI argued the proposed reforms “will encourage efficient, cost-effective transmission investment.”
DOE responded to EEI and PSEG by noting the Needs Study is focused on the physical limitations of the transmission system, “not jurisdictional or regulatory limitations.” FERC rulemaking, therefore, is deemed “out of scope,” DOE said. The department does acknowledge the likely effect of state and federal law, adding modeling of high renewable, high load growth scenarios to the final report.
For example, the study shows the Plains region (roughly corresponding with SPP) would need up to 119% more regional transmission under a moderate load growth, high renewable scenario, but possibly over 400% more in a high load growth, high renewable case.
The Impact
As originally authorized in 2005 amendments to the Federal Power Act, the Transmission Needs Study was called the Transmission Congestion Study, looking only at congestion on the grid. But the Infrastructure Investment and Jobs Act (IIJA) expanded the scope of the report to encompass future needs as well as congestion.
As the first such report, the Needs Study was released as part of a series of DOE announcements of new transmission programs funded by the IIJA, highlighting the department’s role as a catalyst for transmission expansion. DOE is using $1.3 billion in IIJA funds to sign on as an anchor off-taker for three interstate transmission projects, chosen in part based on regional analyses in the Needs Study. (See DOE to Sign up as Off-taker for 3 Transmission Projects.)
DOE also recently awarded $3.46 billion in IIJA funds to 58 grid improvement projects, with the largest award, $464 million, going to five transmission lines in MISO and SPP’s joint targeted interconnection queue (JTIQ) portfolio. Reflecting the Needs Study’s call for a portfolio approach to grid planning, the projects are aimed at improving interregional connections and transfers along the MISO-SPP seams. (See DOE Announces $3.46B for Grid Resilience, Improvement Projects.)
The report’s effect outside the department seems more uncertain, especially given the strong regional and local bias in the comments.
On the one hand, the study’s regional profiles are one of its strong points, laying out where more regional and interregional transmission could improve resilience and bring low-cost renewable power to urban and other areas with high electricity rates.
The study’s approach here is aligned with how RTO grid planning appears to be evolving toward the portfolio approach DOE advocates, as seen in the MISO-SPP JTIQ projects and PJM’s Regional Transmission Expansion Plan Window 3 solicitation. That initiative resulted in PJM recommending a range of projects to expand its system for new renewable generation as fossil fuel plants retire. (See PJM Recommends $5B in RTEP Transmission Projects.)
But the study also notes the majority of transmission projects that have been built in recent years are smaller lines aimed at improving local reliability. The proportion of overall transmission installed to address system reliability needs has grown from 44% in 2011 to 74% in 2020. Interregional projects that can provide multiple benefits beyond reliability ― such as getting more cheap, renewable power online ― still face formidable obstacles, including permitting and financing.
Gramlich sees the report as one piece of an incremental process ― including DOE funding, NIETC designation and FERC rulemaking ― that could drive change in transmission planning, permitting and construction.
“The report could encourage state and federal regulators to get busy … with interregional [transmission],” he said. “It can also encourage private developers ― utilities or independent developers ― to work on lines. … I would think developers building in the transmission [regions] that were highlighted in the report would get a boost with all of the stakeholders and all the utility off-takers or other subscribers to transmission lines. I would think this report would be meaningful for them to encourage their participation.”
FERC on Wednesday approved a PJM proposal to add about $925 million in transmission projects to its Regional Transmission Expansion Plan (RTEP), the bulk of which would address the retirement of the 1,295-MW Brandon Shores generator outside Baltimore (ER23-2612).
The 25 projects the commission signed off on include the $796 million Grid Solutions Package, which was determined to be an immediate-need reliability project to address the Brandon Shores deactivation, as well as $134 million in changes to existing projects — namely the New Jersey State Agreement Approach (SAA) projects — and a $4.69 million cancellation of a previously approved project.
PJM and Talen Energy are in talks to arrive at a reliability-must-run contract to extend Brandon Shores’ operations beyond the June 1, 2025, requested deactivation date; the approved RTEP projects have an in-service date of Dec. 31, 2028.
PJM’s proposal was protested by the Maryland Public Service Commission, the state’s Office of People’s Counsel and the Organization of PJM States Inc. (OPSI), each of which pushed against including the Grid Solutions Package. They argued the RTO improperly designated it to be an immediate need and therefore not holding a competitive process for a solution. The OPC asked FERC to reject the proposal and direct PJM to conduct a “transparent and thorough review of alternatives as well as to engage in a competitive project proposal window, where feasible, for some or all the segments of the Grid Solutions Package.”
The commission determined its review of cost allocation filings is limited to whether the relevant tariff language has been followed, which it found that PJM had, making the protests out of scope. Responding to the argument that OPSI and the PSC made that PJM’s planning process doesn’t adequately account for potential reliability risks posed by generation deactivations, the commission said the RTO and stakeholders are making encouraging steps to consider changes to generation deactivation and transmission planning processes. In recent months, stakeholders have begun discussions at the Deactivation Enhancements Senior Task Force and the Long-Term Regional Transmission Planning Workshop.
Commissioners Mark Christie and Allison Clements each concurred with the order, agreeing the protests were out of scope but noting they raised important issues.
Citing PJM’s “Resource Retirements, Replacements & Risks” report — which raised concerns there will be a significant number of generation deactivations through 2030 that will not be met by currently planned resources — Clements questioned whether there are additional retirements looming that will put ratepayers in a similar bind. She suggested PJM’s Multi-Driver Project planning process could be used to be more proactive and meet potential reliability risks posed by generation deactivations while providing economic benefits and keeping costs low.
“I wonder whether PJM’s extensive reliance on immediate-need reliability solutions such as those at issue in this proceeding is in part a symptom of the failure of the region to carry out proactive, scenario-based multi-value planning,” Clements wrote. “The record in response to the commission’s regional transmission planning proposal suggests that while some local and reliability needs may persist even with greater use of proactive planning, proactive multi-value planning processes can be leveraged to replace or defer reliability projects that would otherwise be needed, at significant value to customers.”
Christie wrote that the growth of state policies and legislation prompting the shuttering of generators raises cost allocation questions for neighboring states in the RTO that may be saddled with a portion of the cost to build transmission necessary to meet demand in the absence of those units. He suggested that such deactivations may be better viewed as public policy projects akin to the transmission being built to interconnect offshore wind under the New Jersey SAA.
“If the resulting transmission projects under protest in this RTEP filing are caused more by Maryland’s policy choices than by organic load growth and economic resource retirements, then a salient question that may be asked is whether these transmission projects are more accurately categorized as public policy projects, essentially the same as the transmission upgrades caused by New Jersey’s offshore wind projects,” he wrote.
While the concerns raised in the protests are valid, Christie said the commission’s hands were tied by the need to prevent potential reliability violations once Brandon Shores goes offline.
“So while I am deeply sympathetic to the concerns expressed by the Maryland PSC, OPSI and the OPC as to the impact on consumers, there is really no practical choice for us but to approve this filing. We simply cannot risk the potentially catastrophic consequences laid out by PJM in its filing. But the states in OPSI, as well as all states in multistate RTOs, may want to consider the broader questions this filing raises, as I have described above,” he wrote.
The Grid Solutions Package comprises a new 500-kV line between the Peach Bottom and Graceton substations and a 230-kV line from Graceton to a new 230-kV Batavia Road substation outside Baltimore. The project also includes one new 500-kV substation. The PJM Board of Managers approved the projects during its July 10 meeting.
The Brandon Shores deactivation is also being addressed by projects included in PJM’s recommended package of proposals submitted during the third competitive window of the 2022 RTEP, which is scheduled to go before the Transmission Expansion Advisory Committee for a second read Dec. 5. The $5 billion proposal also would address increasing data center load in Northern Virginia. (See PJM Recommends $5B in RTEP Transmission Projects.)
A California man has pleaded not guilty in federal court to charges of damaging two transformers belonging to Pacific Gas and Electric in December 2022 and January of this year.
He faces a sentence of up to 50 years in prison and a $500,000 fine if convicted, the Justice Department said.
Peter Karasev, a 36-year-old resident of San Jose, was arraigned in the U.S. District Court for Northern California on Nov. 7, according to a press release, after a federal grand jury indicted him Oct. 19 on two counts of damaging energy facilities and one count of using fire and an explosive to commit a felony. Court records show Karasev was remanded to custody following the arraignment. His trial is scheduled to begin Jan. 30, 2024.
“The FBI is laser-focused on protecting the essential infrastructure that Americans rely on every day, and we and our partners … will use every lawful means to hold anyone who targets that infrastructure accountable,” FBI Director Christopher Wray said in the release.
According to the indictment, Karasev carried out his attacks on Dec. 8, 2022, and Jan. 5, 2023, in San Jose. The first incident occurred at a PG&E facility near the Westfield Oakridge shopping center; the second occurred near Santa Teresa High School about three miles away. Both occurred during the early morning hours in commercial areas occupied by stores and businesses, the department said.
Prosecutors said Karasev built, planted and ignited the explosives involved in each of the alleged attacks himself. Along with “experimenting” with explosives, the government said he also was making methamphetamine in his home during the months before the incidents. His alleged actions caused more than 1,500 San Jose homes and businesses to lose power.
San Jose Police Department officers arrested Karasev “on related state charges” in March, the government said, finding in his home multiple homemade explosive devices “in varying stages of completion,” 300 pounds of explosive precursor materials, firearms and other weapons, and “other hazardous substances.” According to media reports, the state charges include interfering with power lines, arson and child endangerment for conducting illegal activities with three children at home. He was transferred to federal custody to face the indictment.
Each count of damaging a power facility carries a maximum penalty of 20 years in prison, a $250,000 fine and three years of supervised release, while the charge of using fire and explosives carries a mandatory minimum penalty of 10 years to be served consecutively to any imprisonment ordered for the other two charges.
“Damaging our region’s critical infrastructure endangers innocent victims — including our most vulnerable citizens such as the elderly and the sick — and we will not tolerate it,” U.S. Attorney Ismail Ramsey said. “We will vigorously prosecute any malicious attempts to disrupt the power grid.”
Officials have not indicated what Karasev’s motive for attacking the substations might have been. Recent years have seen an increase in attempts to damage electric facilities, with some successful. The attackers’ reasons vary widely; some allegedly believed interfering with electrical service would serve their political ends, as with the group charged in February 2023 with planning to spark a race war by attacking the electric grid in Baltimore. (See Feds Charge Two in Alleged Conspiracy to Attack BGE Grid.)
Other incidents have more prosaic motivations, as with the rifle attacks on substations in Washington state last Christmas. In May 2023, one of the men charged in those attacks pleaded guilty, claiming he and his accomplice wanted to disrupt power as part of a burglary plot against local businesses and ATMs. (See Wash. Sabotage Suspect Pleads Guilty.)
FERC on Thursday rejected parts of a deal Tri-State Generation and Transmission Association had filed to allow the Colorado-based United Power to terminate its membership with the cooperative (ER23-2822).
The firm had signed up to get at least 95% of its needs met by Tri-State through 2050 under the wholesale electric service contract, and its bylaws provide that members seeking early termination must satisfy all of their contractual obligations to the wholesale co-op. Members have to give two years’ notice and make a contract termination payment before they leave.
FERC rejected an earlier attempt from United to conditionally withdraw in April 2022, and just eight days later, the Colorado co-op submitted a nonconditional two-year notice that it still wished to get out of the contract. (See FERC Rejects Conditional Withdrawals from Tri-State.)
Tri-State and United did not agree on the amount of the exit fee and its true-up, the latter of which is meant to protect both sides from over- and under-payments. They also disagreed on whether Tri-State getting the payment was a precondition for United to withdraw and whether Tri-State could terminate the withdrawal agreement if United fails to pay on time.
United argued that the fee is excessive and that because it is based on a pending proposal from FERC, true-ups could take years to come back to it as the case works its way through appeals. Even if FERC quickly approves a calculation leading to a lower fee, United claimed it may not get a refund because of risks to Tri-State’s finances.
FERC found that Tri-State had not proven the withdrawal agreement to be fully just and reasonable, basing that on some of the provisions under the deal.
Tri-State did not demonstrate that it is just and reasonable under the Federal Power Act to automatically terminate the withdrawal agreement and rescind United’s notice of withdrawal to the extent the generation and transmission co-op is found to be outside of FERC’s jurisdiction, which was the case before September 2019 — a decision that has been reaffirmed in court.
“We find that Tri-State has not demonstrated that it is just and reasonable under the FPA to automatically terminate the withdrawal agreement and to automatically rescind United Power’s notice of withdrawal based on a change in jurisdictional status,” FERC said. “We further find that Tri-State has not supported the provision stating that the parties ‘mutually agree’ to rescind the withdrawal notice given that United Power has not agreed to this provision.”
FERC agreed that the deal could be terminated for failure to pay, but it rejected language that would have denied United any chance to fix any late or deficient payment.
The commission agreed that United will have to pay the exit fee that is effective on April 24, 2024, when it is set to withdraw from Tri-State, which currently would be nearly $1.6 billion.
However, the withdrawal penalty calculation method could be changed by FERC in that pending case before that date. The deal also gives 90 days after April 24 for a FERC order on the new method, which would lead to a true-up to the new fee.
New Jersey’s Board of Public Utilities has released its long-awaited dual-use solar proposal designed to incentivize 200 MW of capacity in a three-year pilot program, with the first solicitation of the pilot to be launched in the middle of 2024.
The proposal anticipates the first project selection taking place in the fall of 2024 with the award of 30 MW of dual-use capacity. The proposal, which was released Nov. 10, calls for the award of 70 MW in the second year and 100 MW in the third year.
“Lessons learned from the pilot program and relevant research are intended to serve as the basis for the development of a permanent dual-use program,” the proposal says. And the pilot could be extended by two more years if necessary.
The BPU will hold a public hearing on the dual-use (also known as agrivoltaics) proposal Nov. 29 and will accept written comments until Dec. 13.
The proposal comes amid concerns in New Jersey, as in other states, that farmland could be lost to solar projects as struggling farmers find clean energy more lucrative than cultivating the land. Farms in New Jersey are under pressure as the development of residential and warehouse projects encroaches on rural areas, and dual-use projects are a way to combine farming and solar use, and so preserve farmland. (See NJ Solar Push Squeezes Farms.)
“Dual-use solar can provide farmers with an additional stream of revenue, contributing to farm financial stability and allowing for continued agricultural or horticultural production of land while increasing the production of clean energy,” the proposal states.
The New Jersey Agricultural Experiment Station (NJAES) and Rutgers University are midway through a $2 million study into the effect on crops and animals of solar projects and farming co-existing at three sites around the state. (See NJ’s $2M Agrivoltaics Study Advances.) The Rutgers Agrivoltaics Program helped design the BPU’s pilot proposal.
To protect farmland, the proposal requires dual-use pilot projects to be located “only on lands that have had at least three most recent years of continuous agricultural or horticultural use.”
The plan also requires that land hosting a dual-use project continue to be used for agriculture or horticulture and that projects include “a method of ensuring that the presence of the solar electric generation equipment does not result in a substantively negative change or reduction in the quality of the land that would impair its agricultural or horticultural usage.”
“Staff proposes that any pilot program participant that does not maintain active agricultural or horticultural use of the land would risk forfeiture of future dual-use incentive payments,” the proposal states.
Size Diversity
The pilot is based on the guidelines for an agrivoltaics program in the state set out in a bill signed by Gov. Phil Murphy (D) in July 2021. The bill, A5434, required that the BPU, in consultation with the New Jersey Department of Agriculture, adopt rules and regulations for the pilot program within 180 days, or by the end of January 2022.
The proposal provides incentives for dual-use solar projects in the form of New Jersey Solar Renewable Energy Certificate under the state’s Successor Solar Incentive (SuSI) program. So the incentives for dual-use projects smaller than or equal to 5 MW would be set administratively by the BPU and incentives for projects greater than 5 MW would be determined by a solicitation held under the Competitive Solar Incentive part of the SuSI program.
BPU staff suggests the state limit dual-use project sizes to 10 MW, but adds that if several projects of the maximum size are proposed, the agency should select projects that provide a variety of size, location or interconnection points.
It adds that a minimum size of project may be needed because smaller projects likely would not offer much helpful information that could be used in the program evaluation.
The projects also will be judged on the developer’s plan for the project at the end of its life cycle, the proposal states.
“Staff envisions the evaluation of pilot project proposals will take into account the extent to which applicants plan to follow an established set of guidelines or best practices that facilitates farming following decommissioning,” the proposal states.
ISO-NEoutlined how FERC’s time extension for Order 2023 compliance will affect its proposal, at a meeting of the NEPOOL Transmission Committee on Nov. 9.
The RTO plans to file on April 1 with a proposed effective date of May 31, upon which it would issue study agreements to interconnection customers that are due 60 days later, followed by the beginning of the cluster study. Customers with valid interconnection requests as of May 1 would be able to enter the transitional cluster.
“Interconnection requests that are not valid and have not been assigned [a] queue position as of [May 1] will be withdrawn by the ISO without further opportunity to cure any deficiencies,” said Graham Jesmer, ISO-NE regulatory counsel. “The ISO will not accept any interconnection requests submitted after [May 1] until the first cluster entry window opens in 2025.”
Interconnection requests in the system impact study (SIS) phase as of May 1 will continue through the May 31 effective date. “Results of those studies will be provided for information purposes only and will not affect a project’s status with respect to the transitional cluster study,” Jesmer said.
Alex Rost, ISO-NE manager of resource qualification, discussed how Order 2023, along with the delay of Forward Capacity Auction 19, will affect new resources looking to establish capacity network resource capability (CNRC) and capacity network import capability (CNIC). Complying with Order 2023 means moving the process for gaining CNRC and CNIC from the Forward Capacity Market to the cluster study process.
Rost noted that under ISO-NE’s proposal to delay FCA 19, resources lacking a capacity supply obligation (CSO) would be able to submit their qualification materials using the original capacity qualification schedule, referred to as “supplemental qualification.” (See NEPOOL Votes to Delay FCA 19.) The current process for achieving CNRC and CNIC would apply until Sept. 1, 2024.
“After Sept. 1, 2024, resources subject to the ISO’s interconnection procedures can still obtain a CSO in FCM auctions but will not be able to establish CNRC/CNIC by obtaining CSO in FCM auctions,” Rost said.
Stakeholder Proposals
Representatives of the clean energy development companies New Leaf Energy and Cypress Creek Renewables also presented recommendations to ISO-NE on its Order 2023 compliance at the meeting.
Cypress recommended the RTO require complete site control for interconnection and generator facilities at the time of executing interconnection agreements to reduce speculative projects.
The company also said ISO-NE should take steps to preserve flexibility around “electrically proximate” points of interconnection, allow interconnection customers to make transition study deposits via letter of credit, and stagger the start of subsequent clusters to increase the amount of information available to interconnection customers.
New Leaf expanded upon the recommendations it made to the MC in October, stressing the importance of allowing late-stage interconnections studies to proceed for as long as possible to prevent project delays and limit the number of projects in the transitional cluster study. (See ISO-NE Provides More Detail on Order 2023 Compliance.)
“We respectfully ask ISO-NE to provide the committee with an assessment of which queue positions with an SIS in-progress have an estimated SIS completion date prior to the commencement of the transitional studies … and whether ISO-NE could somehow ‘commit’ to completing those studies,” New Leaf said.
ALBANY, N.Y. — The New York State Reliability Council Executive Committee last week approved for industry comment interconnection standards for inverter-based resources larger than 20 MW (Proposed Reliability Rule 151).
“The need for [IBR standards] has grown since April,” said Roger Clayton, chair of the NYSRC’s Reliability Rules Subcommittee, who noted that renewable projects in NYISO’s queue grew from about 57 GW in spring to 120 GW on June 30. “This is an urgent need.”
The committee, which approved PRR 151 at its Nov. 9 meeting, has been working with the Reliability Rules Subcommittee to fill gaps in NYISO’s current interconnection criteria for IBR resources. The proposed rules would take effect in all interconnection projects following, excluding the current Class Year 2023. The rule, which aligns with the recently approved IEEE Standard 2800-2022, guides the ISO to incorporate specific performance criteria, databases and model validation methods for IBRs within its authority. (See “Inverter-based Resources Standard,” NY State Reliability Council Executive Committee Briefs: June 9, 2023.)
IBRs are pivotal because they convert direct current from solar and wind into alternating current, the standard form of power for the grid. IBRs also manage the flexible charging and discharging of batteries and allow very fast ramping and frequency response.
Advanced capabilities of IBRs, such as fault ride-through and voltage regulation, also ensure the reliability and quality of power. Yet IBR integration presents new challenges due to their variability and the need for innovative control strategies, as revealed in numerous NERC disturbance reports since 2016. PRR 151 addresses this reliability risk by requiring developers to attest that their plants meet the IEEE 2800-2022 standards to ensure these resources perform reliably. (See “Inverter-based Resources Standard,” NY State Reliability Council Executive Committee Briefs: June 9, 2023.)
Clayton said, “we’re at the leading edge of this,” adding it was important that New York “get something on the books” because the interconnection queue keeps growing and the projects seeking interconnection keep getting larger.
The NYSRC says adopting PRR 151 will safeguard the New York Control Area’s reliability as it pivots toward renewable resources, protecting the state from potential system supply disruptions that were seen in other states like Texas, Utah or California where IBRs failed during routine transmission disturbances.
“We’ve gone through this with NYISO in a very detailed manner,” Clayton said, in reference to how the ISO has been integral in making PRR 151 “very focused and very clear. In addition, the changes were sensitive to other stakeholder comments received during the initial posting.”
Chris Sharp, senior compliance attorney with NYISO, said the rule would be applied by the ISO “on a rolling basis,” with projects examined for compliance when submitting an interconnection application.
Zach Smith, vice president of system and resource planning at NYISO, said ISO staff does not anticipate any tariff revisions will be necessary to implement PRR 151. “Coincidentally, this is coming at a handy time,” he said, referring to the ISO’s efforts to reconfigure its interconnection processes to comply with FERC Order 2023. (See NYISO Stakeholders Question Proposed Interconnection Timelines, Deposit Rules.)
Michael Mager, a partner at Couch White who represents Multiple Intervenors, a group of large industrial, commercial and institutional energy consumers, opposed the approvals, saying the changes under the new model for external emergency assistance were excessive.
The NYSRC will consider the final study report as part of its deliberations on the IRM for the next capability period at its December meeting.
CAISO is moving quickly to gain approval for a proposed transmission line that would allow California to meet targets for tapping Idaho wind resources and help both states bolster their resource adequacy profiles.
The ISO is seeking to acquire enough entitlements on the Southwest Intertie Project–North (SWIP-N) to import 1,000 MW of wind energy from Idaho, aligning with the plans to access Idaho wind that have been set out in utility integrated resource plans filed with the California Public Utilities Commission.
“Transmission development is needed to access out-of-state wind resources and this project is the only known transmission project that can enable access to Idaho wind resources,” CAISO said in a slide presentation shown during a Nov. 7 stakeholder meeting to discuss SWIP-N, which is being developed by LS Power subsidiary Great Basin Transmission (GBT).
SWIP-N would link to the One Nevada (ON) line at Robinson Summit in Nevada and run north 285 miles into Idaho, providing 2,070 MW of transfer capacity southbound and 1,920 MW northbound. The ON line is connected to the Desert Link, which extended CAISO’s operational boundary to the Harry Allen substation north of Las Vegas when it went into service in 2020.
The entitlement structure for SWIP-N would provide GBT with 1,117.5 MW of north-to-south capacity and 1,072.5 MW of south-to-north capacity, with the balance in both directions allocated to Nevada-based NV Energy.
CAISO is considering a proposal to leverage a transmission use and capacity exchange agreement (TUA) between NV Energy and GBT that would allow the ISO to acquire most of GBT’s entitlements on the SWIP-N line and ON line rather than building a new, roughly 500-mile transmission line to reach Idaho’s resources. Under the plan, Idaho Power would assume 500 MW of south-to-north capacity on the line to support winter RA needs.
The plan was spelled out in a Nov. 1 letter Idaho Power sent to CAISO CEO Elliot Mainzer expressing interest in partnering with the ISO to fund SWIP-N as a “joint regional policy-driven project.” It would also give the Boise-based utility access to the Desert Southwest wholesale power market.
Under the plan, CAISO and Idaho Power would share the more than $1 billion cost for the line — or about $3.8 million per mile, which the ISO said is close to the per-mile costs for other competitively procured transmission projects in the region. The ISO would fund 77.2% of the project, with Idaho Power picking up the rest. Based on the TUA, CAISO would pay no additional costs for assuming GBT’s entitlements on the ON line.
“Transmission infrastructure is a primary key enabler to a cost-effective, reliable and clean energy future. Idaho Power believes that cost effective transmission is a no-regret investment,” Idaho Power said in the letter. “All feasible scenarios related to electric grids of the future will continue to heavily utilize interregional transmission infrastructure.”
During the Nov. 7 meeting, CAISO told stakeholders SWIP-N will help Idaho and California meet their resource portfolio needs while sharing project costs, reducing the cost to California ratepayers. The ISO also said the project has the advantage of being shovel-ready.
Still, construction of SWIP-N is contingent on Idaho Power and GBT reaching an agreement that is conditioned on CAISO’s approval of the project, FERC’s approval of the agreement between Idaho Power and GBT, and an Idaho Public Utilities Commission (IPUC) determination that the project will provide sufficient benefits to Idaho Power to justify the cost.
If CAISO approves the project, Idaho Power will file for approval with the IPUC by year’s end and the project could begin operating by 2027.
Stakeholder Feedback
CAISO stakeholders participating in the Nov. 2 meeting generally supported the SWIP-N proposal.
“We appreciate the CAISO’s due diligence in exploring these opportunities to reduce the overall project cost to California ratepayers,” said Pushkar Wagle, managing consultant at Flynn Resource Consultants. However, Wagle questioned whether the project’s cost estimates were being downplayed.
“You presented the numbers in terms of dollars per mile; that’s clearly one metric to look at it. Another metric is what’s dollars per megawatt or dollars per kilowatt-year?” Wagle said. “The way the models are run is basically they’re trying to minimize the overall cost of procurement, so if you plug in these numbers, you might get totally different answers.”
Biju Gopi, CAISO senior manager of transmission interface coordination, emphasized that the cost shouldn’t be a significant concern. “Resource choices are generally stable and cost is not so much a factor as compared to other elements like resource potential limits [or] transmission limitations,” he said.
But Kanya Dorland, senior analyst with CPUC’s Public Advocates Office, echoed Wagle’s comments.
“SWIP-N has been studied for almost 10 years as both a public policy and economic project and each time it’s determined that its costs outweigh the benefits,” Dorland said. “It sounds positive that Idaho Power would contribute, but is the benefit-cost ratio greater than one with this new arrangement, or would it be better with a [Department of Energy] loan?”
CAISO requested that GBT pursue a DOE loan to finance construction of the project, but Gopi was not aware if it was awarded.
Gopi again highlighted that the goal of the project — to access Idaho’s wind resources — outweighs potential costs.
“We’re pursuing this project not as an economic-driven project but as a policy-driven project,” Gopi said. “CPUC requirements do require us to plan for integrating wind resources from Idaho into California.”
CAISO expects to seek conditional approval for SWIP-N from the board by early December. Full approval is conditioned on Idaho Power receiving IPUC approval for the line by June 2024, GBT applying to become a participating transmission owner in the ISO by July 1, 2024, and FERC’s acceptance of GBT’s transmission owner tariff and transmission revenue requirement rate structure.
Stakeholder comments on the proposal are due to CAISO by Nov. 21.
LITTLE ROCK, Ark. — SPP has its strategic priorities, as do all grid operators, and resource adequacy is one of them.
It is also the RTO’s No. 1 strategic priority.
“It’s all over your agenda today,” SPP CEO Barbara Sugg said in opening the recent meeting of the Regional State Committee (RSC), which comprises the RTO’s state regulators. “It’s been a No. 1 priority for us, particularly since Winter Storms Uri and Elliott.”
The Resource and Energy Adequacy Leadership (REAL) Team, a cross-section group of regulators, directors and stakeholders, is the answer. After inside jokes during the team’s first few months (“Yes, we will really be meeting soon.”), the team has set an aggressive schedule in assessing SPP’s current resource adequacy construct and providing guidance and policy recommendations to ensure sufficient energy is available to meet load requirements.
The group, led by Texas Public Utility Commissioner Will McAdams, and its subgroups brought two key resource adequacy policies for approval during the October governance meetings. Next year, it plans to present a maintenance outage policy, value-of-lost-load and expected unserved energy metrics and associated usage policies, and a winter planning reserve margin.
“I am particularly pleased with the REAL Team,” Sugg said. “What really excites me about this is it is a joint committee, if you will, with seats at the table for the RSC and the board and the stakeholders. I personally would love to see this continue as a longstanding committee in the future because I think there is tremendous value to be gained by us sitting around the table and working together.”
During what RSC President and Kansas Corporation Commissioner Andrew French called a “lively meeting with lots of opinions shared,” the regulators on Oct. 30 approved two revision requests brought forward by the REAL Team that lay out a performance-based accreditation (PBA) policy (RR554) for conventional resources and effective load-carrying capability (ELCC) accreditation (RR568) for wind, solar and storage resources. The Board of Directors approved the RRs the next day.
“It’s been a real innovative and valuable approach to problem solving,” Sugg said during the RSC meeting. “I’m sure there are other problems we can solve together, and I look forward to that. The team has a work plan, and we’ll be bringing more resource adequacy policies in the coming quarters as well. That collaboration is outstanding.”
“The key thing from the REAL Team is to improve the cycle time between the key working groups and the committees to ensure we move through these very critical decisions as quickly as possible,” SPP Director John Cupparo said. “I would encourage the key folks involved in the REAL Team and around the team to take the opportunity to kind of clarify the relationships between the working groups, because [that] will ultimately benefit all of us as these decisions continue to come forward.”
RR568 is a response to FERC’s rejection earlier this year of SPP’s first attempt to add ELCC (the amount of incremental load a resource can dependably and reliably serve during peak hours). The revision reduces a three-tiered structure to just two, firm and non-firm transmission service. Staff will study only firm service in its ELCC analysis. (See FERC Grants Rehearing of SPP Capacity Accreditation Proposal.)
RR554 was approved after restoring the use of seven years of historical data, rather than 10, in calculating conventional resources’ accredited capacity. The Markets and Operations Policy Committee had rejected the seven-year figure and endorsed 554 with 10 years of historical data.
SPP’s Market Monitoring Unit had initially proposed five years of historical data but settled on the seven-year compromise during a September meeting with the REAL Team. (See SPP REAL Team Compromises on PBA, ELCC Revisions.) Smaller utilities have sided with the 10-year figure, saying it would give them and their smaller fleets more time to meet resource requirements.
The board also approved a Supply Adequacy Working Group (SAWG) policy paper on demand response and its planned direction on fuel assurance, both of which previously were endorsed by the RSC and MOPC. They will be converted into RRs and brought back to the board for final approval.
The first policy will facilitate diverse DR programs by considering the potential for increases in large loads that may claim its accreditation. SAWG members say the grid operator must accurately accredit DR resources according to their reliability contribution and develop qualification standards to drive consistency.
The fuel assurance policy will incorporate PBA weighting based on critical system periods and considers modifications to the out-of-management-control exceptions related to fuel-related outages. The SAWG also will consider a policy for PBA and ELCC adjustments to reflect new reliability investments and recommends SPP improve operational dispatch strategies to start units before extreme cold weather and keep them online.
RSC, Board OK Sunflower Waiver
Sunflower Electric Power finally was given some potential relief for congestion from renewable resources in its pricing zone when regulators and the directors both approved RR584, directing SPP to make a Federal Power Act Section 205 filing at FERC that would regionally allocate four Sunflower upgrades on a prospective basis.
The cooperative last year submitted the waiver request from SPP’s base-plan allocation methodology for upgrades between 100 and 300 kV, or byway projects. The process allocates one-third of the cost of byway projects to the RTO’s full footprint, with customers in the transmission pricing zone where the project is built being allocated the rest. “Highway” projects — those larger than 300 kV — are allocated RTO-wide.
The Members Committee’s advisory vote to the board passed 9-8, with six abstentions. Members argued against the waivers as they did during the MOPC meeting, saying deconstructing the allocation process with one-off reassignments sets a troubling precedent for future requests.
Al Tamimi, Sunflower’s COO of transmission, thanked the RSC for debating the issue before it came to the board, saying it will buy time until a more comprehensive solution can be developed.
“This issue started back in 2018 and 2019. It did not come out of nothing,” he said of one of the Holistic Integrated Tariff Team’s (HITT) major recommendations. “We had years in the HITT discussing this issue, and we came up with two solutions for cost allocation to maintain the fairness of highway/byway. The one-off thing really needs to be one-off, at this point, until we figure out the whole big plan because the highway/byway fundamentals don’t work in Sunflower … when you’re exporting 80 to 90% of massive amounts of power while you’re paying 70% of the cost.”
The four upgrades will provide $13 million in annual revenue requirement.
French addressed comments from members who noted the committee appeared to be sidestepping MOPC.
“One of the motions that we passed sent some direction to the [RSC’s Cost Allocation Working Group] and the SPP staff, where previously the REAL Team had sent some very similar direction to the [Supply Adequacy Working Group],” French said. “I don’t know that the intent of the RSC was to cut anybody out, and I hope there will still be collaboration and cross-pollination between all those groups working together to give us the most informed feedback we can get.”
In July, FERC unanimously reversed a 2022 decision that established a process for SPP to allocate “byway” transmission projects on a case-by-case basis without prejudice. SPP plans to look at the more comprehensive process and make a filing early next year. (See FERC Reverses Course on SPP Byway Cost Plan.)
Sunflower, a “wind-rich” cooperative that long has felt unduly burdened with transmission costs for renewable energy that benefits others, has filed a rehearing request with FERC and asked the D.C. Circuit Court of Appeals to review the case (ER22-1846).
MEAN Appeal of ITP Fails
The board and members approved SPP’s 2024 Integrated Transmission Plan and its 10-year assessment, but it didn’t take up an appeal from the Municipal Energy Agency of Nebraska (MEAN) over a project that had its notification to construct (NTC) withdrawn from the portfolio.
MEAN’s Brad Hans argued the $92 million, 48-mile, 115-kV joint economic project in Nebraska between the Western Area Power Administration’s Rocky Mountain Region and the Nebraska Public Power District was necessary. He noted the ITP identified the western half of Nebraska as a problem area and the public agency, with only two load nodes, has seen day-ahead prices as high as $200/MW, popping to $300 to $600 during congested periods.
“This has a direct impact on the communities we serve in western Nebraska,” Hans said. “When you see the congestion, as we’ve seen in past three years, elevating to the levels and to the extent it has, it just compounds the rate pressures in this area.”
Hans apologized for the appeal, saying he realized it was not the “preferred way” to keep the project’s NTC.
“I can assure you, MEAN is just an acronym. It’s not our disposition,” he said.
David Kelley, SPP’s vice president of engineering, said staff don’t disagree with MEAN’s concerns.
“We agree there is an issue that warrants attention. We think it requires a little more time to bake,” Kelley said, saying the project will be studied again during the 2024 ITP cycle. “I’m pretty confident we’re going to find something that addresses the solution.”
“We’ve gotten a clear indication that there’s a need here. That doesn’t appear to be in dispute,” the Advanced Power Alliance’s Steve Gaw said. “I worry about this setting a precedent, where a variety of entities, not liking the result, can come into a [working group] and push back hard. Then, we’re sitting here with another delay, when that’s costing us money.”
SPP since has pulled another economic project from the ITP portfolio, a 38-mile, 345-kV line north of Oklahoma City with projected costs of $110 million. The project had an NTC with conditions (NTC-C) but has upgrades that would qualify as competitive upgrades and other upgrades that won’t.
Staff will re-evaluate the project’s refined cost estimates to determine whether the competitive upgrades can be authorized for construction.
The 2023 ITP addresses reliability and economic issues on its seams. It recommended NTCs for 44 projects before the Oklahoma line had its NTC-C pulled. The portfolio included 150 miles of new transmission — 51 miles for 345-kV lines — and 93 miles of rebuild for a total engineering and construction cost of $735.5 million and a reduced 40-year adjusted production cost of nearly $3 billion.
The assessment indicates the footprint’s wind growth continues to outpace ITP projections. The 2023 ITP’s emerging technologies case projects 46.1 GW of in-service wind in 10 years, a nearly 25% increase from the 10-year assessment just two years ago. SPP had just over 37 GW of in-service wind resources when 2023 began.
Celebrating $464M DOE Grant
Staff and stakeholders celebrated the U.S. Department of Energy’s recent $464 million grant for the SPP-MISO Joint Targeted Interconnection Queue (JTIQ) portfolio with a round of applause and thanks to stakeholders involved in the application.
“I think this is such a great thing for SPP and for MISO, and for the DOE and NERC to see the value at these two regions working together to solve some of these seams issues,” she said. “There’s a lot of work that goes into receiving federal money; there’s a lot of work that goes into the ask; and then there’s a lot of work that goes into the receipt of it and the spending on it.”
Sugg singled out Minnesota Public Utilities Commissioner John Tuma and other Gopher State staffers for “helping us pave the way.” The Minnesota Department of Commerce and the Great Plains Institute took the lead on the JTIQ’s submission, one of 700 that DOE received. Kelley thanked regulators, governor’s offices and other stakeholders for providing letters of support.
FERC Commissioner Allison Clements and DOE both heaped praise recently on the JTIQ, which is designed to ease transmission limitations along the RTOs’ seam by interconnecting new generating resources.
Clements, in her concurring opinion to Order 2023, said the “promise of a forward-looking approach” to a streamlined interconnection process is “becoming clear” through the “pioneering” work by SPP and MISO. A draft DOE report on transforming interconnection says the JTIQ study shows that “proactively studying a larger set of generation interconnection requests offers substantial cost and time savings, identifies more optimized network upgrades and reduces uncertainty for the resource developers.”
“The real work begins now because $464 million is not coming with no strings attached,” Kelley said.
Staff over 700 with Budget Approval
The Finance Committee’s recommended 2024 operating budget passed easily, resulting in a $192.1 million net revenue requirement and a 2.5% increase in the administration fee, from 44.8 cents/MWh to 45.9 cents/MWh.
The budget projects $275.3 million in operating expenses next year and $17 million in capital allocation. SPP’s headcount will increase to 707, primarily because of work on resource adequacy, responding to the December 2022 winter storm and western expansion. The grid operator’s staff numbered 676 in 2022.
Several members said the growth of stakeholder groups addressing increasing responsibilities has put a strain on their staffs and will affect their ratepayers. SPP staff responded with an overview of the methodology used to reduce spending and the rigorous senior management review and analysis that led to the final recommendation.
Golden Spread Electric Cooperative’s Mike Wise, a longtime member of the FC, said the group’s questions of the budget to senior staff was “probably greater than in any other year.”
“I felt very comfortable with their responses and their concerns,” he said. “The operating environment that SPP is in right now is really difficult. We are asking them to do a whole lot of things with less and less. The RTOs are fighting trying to get engineers … and raising the salaries. For SPP to hold on to its senior staff and its educated and experienced engineering force is a real testament.”
Consent Agenda Flies
The board’s consent agenda approved the 2023 annual violation relaxation limits (VRLs) analysis; a more than $16 million baseline decrease (20.2%) for a 230-kV Basin Electric Power Cooperative project in North Dakota; a 47% baseline increase of $12.3 million for a 345-kV American Electric Power-Oklahoma Gas & Electric project in Oklahoma; the Generation Interconnection Advisory Group’s conversion from a user forum; and several recommended appointments to stakeholder committees:
Nebraska Public Power District’s Laura Kaputska to the Finance Committee.
Omaha Public Power District’s Joe Lang to the Human Resources Committee.
Evergy’s Denise Buffington and Arkansas Electric Cooperative Corp.’s Andrew Lachowsky to the Strategic Planning Committee.
The consent agenda also included a pair of RRs:
RR572: updates the planning criteria with a definition for “qualified change” that reflects the new NERC mandatory reliability standard FAC-002 (Facility Interconnection Studies).
RR579: adds language to the market protocols to clarify that in the event of a 0-MW effective limit, those constraints will have the highest VRL value ($/MW).
