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October 30, 2024

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MISO Members Approach Revised NIETCs with Hope, Caution

MISO members were both apprehensive and hopeful over the Department of Energy’s new plan to designate National Interest Electric Transmission Corridors (NIETCs) to spur transmission expansion.

MISO Advisory Committee members discussed the topic at their Aug. 16 teleconference.

The DOE in May issued a notice of intent that it might unroll a new process to designate NIETCs, which would fast-track permitting and financing for transmission projects under development. (See States, RTOs Caution DOE on Transmission Corridors.)

The Union of Concerned Scientists’ Sam Gomberg said MISO’s Environmental Sector believes the rule will “expand and accelerate” the building of a system that is prepared for future needs. He also said the rule seems “responsive to past failures” of the federal government to involve itself in transmission siting.

Wisconsin Public Service Commissioner Tyler Huebner said MISO state regulators are split over the proposed rule, with some enthusiastic over how it could spur lines that span multiple planning regions but others saying such a process would be administratively burdensome and a means to subvert existing state routing authority.

During an Aug. 14 Organization of MISO States meeting, Texas Public Utility Commissioner Lori Cobos said Texas is “concerned, very concerned” over the DOE potentially nominating corridor projects that ratepayers will finance.

“What we don’t want this to become is an adversarial process,” Gomberg said, adding that the DOE should recognize states’ primacy in permitting and siting.

MISO Transmission Owner representative Stacy Herbert said the DOE should make sure its designation process “does not interfere with, but rather complements” regional and interregional transmission planning.

Huebner said some MISO state regulators believe NIETCs will be key to getting interregional lines built.

“We think this might be the best value add of the process,” he said.

Huebner said the DOE could invite states to propose NIETCs locations. He said if multiple states propose adjacent locations, that could build toward larger, national designations.

Gomberg said he worried the federal government would use its new permitting authority too little.

“I’m going to be blunt here. I’m not convinced that FERC has the guts to move forward with anything but the most egregious needs on the system,” he said.

Gomberg also said while members of the MISO Environmental Sector aren’t expecting the federal government to be the architects of a “grand national grid” through its authority, there are going to be clear opportunities for corridors.

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FERC Rules on Four Issues from Tri-State Rate Filing

FERC on Tuesday affirmed, in part, and reversed, in part, four disputes arising from Tri-State Generation and Transmission Association’s first jurisdictional rate filing before the commission in 2019 (ER20-676).

The issues were set aside from a settlement approved by the commission in August 2021. (See FERC Approves Tri-State’s 1st Major Rate Case.)

Before the year was up, FERC directed further hearing procedures on the four reserved issues related to wholesale power service rates for Tri-State’s 43 members. The presiding judge issued an initial decision in May 2022.

The commission agreed with the judge’s decision on the first reserved issue that Tri-State is subject to FERC Order 888’s functional unbundling requirements.

It also affirmed in part and reversed in part the initial decision on the third reserved issue, which determined whether Tri-State can apply a transmission demand charge to member United Power’s storage resources. FERC agreed that United Power must pay the charge based on gross load and that Tri-State must reimburse the cooperative for overcharges.

However, it reversed some of the determinations describing how Tri-State must calculate the appropriate reimbursements and refunds and the judge’s finding that United Power doesn’t need to pay a late charge for not meeting the payment’s deadline.

FERC reversed in part and affirmed in part initial decisions in the other two reserved issues: Tri-State’s cost-allocation standards applicable to certain costs, and whether the G&T’s community solar program is just, reasonable, unduly discriminatory and/or preferential in applying a $0 add-back charge to program’s projects.

The commission disagreed with the decision that Tri-State must apply an any-degree-of-integration test and the seven-factor Mansfield test (a case-by-case analysis of local distribution’s indicators) to determine cost allocation. It said that the tests are applicable standards but are not necessarily the exclusive means for determining appropriate cost allocation.

FERC also agreed Tri-State’s application of the add-back charge to load served by community solar projects is inappropriate. However, it found the charge to be unjust and unreasonable, rather than unduly discriminatory as the judge had decided.

The commission gave Tri-State 45 days to make a compliance filing outlining how it will reimburse United Power for overcharges in one of the reserved issues.

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DC Circuit Affirms FERC Order on PJM MSOC

The D.C. Circuit Court of Appeals has upheld FERC’s 2021 order reworking PJM’s market seller offer cap (MSOC) to replace the default offer cap with a unit-specific review process (21-1214).

Tuesday’s decision overrules challenges from a series of generation companies arguing that the order deprived them of their right to set their own rates, didn’t allow for a full accounting of the financial risks that come with a capacity obligation and didn’t adequately explain why it eliminated the default offer cap instead of modifying it. (See Judges Skeptical of Capacity Sellers in PJM Offer Cap Dispute.)

The order was focused on increasing the instances in which generators’ offers will be subject to unit-specific review to determine if market power mitigation is necessary, particularly in the case of the marginal resource clearing the capacity market. With the default offer cap in place, as much as 99% of offers fell below the cap and were determined to not require mitigation, a rate the commission determined was too high (EL19-47).

The component the commission believed to be behind the high offer cap was the number of performance assessment intervals (PAI) a generator could expect to face on average per year. The order establishing the capacity performance (CP) construct pegged the anticipated number of intervals at 360 each year. However, in a complaint arguing that the offer cap was too high, the Independent Market Monitor said the subsequent four years saw 24 intervals. (See FERC Backs PJM IMM on Market Power Claim.)

Instead of basing when an offer is subject to unit-specific review on whether the marginal cost of taking on a capacity obligation — the resource’s avoidable cost rate (ACR) — exceeded the amount it expected to earn during PAIs, the commission’s 2021 order eliminated the default offer cap with unit-specific review of resources’ ACRs.

The court disagreed with the generators that they could not set their own rates under the new paradigm, finding that capacity auction offers are not rates, as they are submitted to PJM, rather than filed with FERC, and are confidential rather than public. Although the Monitor can suggest an alternative offer for PJM to consider, the RTO still holds the “primary role” in selecting an offer, the ruling states, and generators also can appeal to FERC if they disagree with the selection.

“To summarize the interaction, suppliers can submit their offers to PJM regardless of the Independent Market Monitor’s views, then ask the commission to referee if a dispute persists. As such, the current tariff and September 2021 Order make quite clear that suppliers do not play second fiddle when their proposed offers deviate from that of the Independent Market Monitor,” the ruling states.

The court also sided with the commission in finding that generators retain flexibility when accounting for the risks that come with taking on a capacity obligation. Past orders have made clear that costs that also would be incurred if the generator participated only in the energy market cannot be included in capacity offers and that by not outlining an “exhaustive” list of all costs that could be included in the ACR, the order does provide flexibility.

The generators’ arguments that alternatives to eliminating the default offer cap had not been given due weight by the commission also were denied. The court pointed to FERC’s argument in its 2021 order stating that while alternatives would have recalibrated the cap, they still would have resulted in a value so high that only a small number of offers would be subject to review and therefore would not have resolved the issue.

While it did not join in the appeal to the court, PJM filed a request for FERC to rehear its order arguing that unit-specific review of all resources could lead to over-mitigation of capacity resources. (See PJM Requests Rehearing of MSOC Change.)

“The harm of overmitigation under a unit-specific ACR approach is real and will inhibit the ability of capacity market sellers to base their offers on their respective cost estimates and assumptions about what is likely to occur three years in the future,” PJM said in its filing. “This is because each capacity market seller’s evaluation of risk relating to actual costs and revenues varies for various resources … and it is not appropriate for PJM or the Market Monitor to substitute their assessment of the risks for the capacity market seller’s demonstrable assessment of the risks.”

EPSA Says MSOC Structure Threatens Reliability

In a statement released Tuesday, the Electric Power Supply Association (EPSA) argued that the ruling leaves intact a capacity market that interferes with generators’ ability to earn an adequate return on their investments needed to service the grid reliably. The association joined Vistra, Constellation, LS Power, Calpine, Talen Energy and the PJM Power Providers Group in petitioning the court to overturn the commission’s order.

“The changes approved by the court to PJM capacity offers undermine the ability of private investors and developers to assume risk and earn an adequate return — jeopardizing PJM’s ability to procure sufficient generation to meet anticipated demand in today’s challenging landscape,” EPSA President Todd Snitchler said. “This decision from the court adds urgency to the Board-directed stakeholder process underway at PJM to develop reforms that substantially address the flaws in the capacity market — the vehicle by which the RTO ensures resource adequacy and system reliability.”

He noted PJM has raised alarms that the expected pace of resource retirements may exceed new resources coming online and threaten reliability, a dynamic he said will be exacerbated by the design of the capacity market.

“Now more than ever, with at least 40 GW of generation flagged by PJM for being at risk of retirement without sufficient replacement, it is critical that the resources needed for reliability have adequate incentives to stay running,” he said. “Yet FERC and PJM are once again making it harder for markets to procure much needed resources rather than enable greater participation of resources that provide reliability.”

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DOE: IRA, IIJA Could Add 475 GW of New Solar to US Grid by 2030

By 2030, the combined impact of the Inflation Reduction Act and Infrastructure Investment and Jobs Act could add up to 475 GW of new solar and 250 GW of new wind power to the U.S. electric grid, according to a new report from the Department of Energy.

Released on the first anniversary of the IRA’s enactment, the report looks at the combined impacts of the two laws across a range of key economic and climate measures from 2022 to 2030. Top line figures include:

    • electric bill savings for U.S. families of $27 billion to $38 billion, and a 13 to 15% reduction in commercial electricity bills for American businesses;
    • a cut in U.S. oil imports of 44 to 59%, which would also cut spending on imported oil by 13 to 22%;
    • an increase in clean energy — including nuclear, hydropower, geothermal and fossil fuels with carbon capture — on the U.S. grid from 42% in 2022 to 72 to 81% by 2030;
    • sales of zero-emission vehicles rising from 8% of total car sales today to 49 to 65% by 2030; and
    • a 35 to 41% drop in greenhouse gas emissions over 2005 levels versus a projected 27% decrease without the two laws.

The combined impacts of the IRA and IIJA are expected to cut U.S. greenhouse gas emissions 35% to 41% over 2005 levels by 2030. Without the laws, emissions would drop 27%. | DOE

The mostly rosy picture of the laws’ impact is based on new modeling by DOE incorporating the potential effects of the IRA and IIJA into its National Energy Modeling System, with scenarios projecting “moderate” and “advanced” uptake of the laws’ provisions. However, looking at the report’s technical documentation, it is unclear if the new modeling takes into account ongoing challenges to clean energy deployment ― specifically, permitting, interconnection and transmission.

Still, President Joe Biden pointed to many of the figures as he celebrated one year of the IRA being law at the White House on Wednesday, calling the law “one of the biggest drivers of jobs and economic growth this country has ever seen.”

IRA solar

The president spoke to a packed room of supporters. | The White House

Biden said the tax credits in the law will break the clean energy industry’s long dependence on China for a range of equipment, drawing manufacturing and supply chains back to the U.S. “We’re bringing critical supply chains and technologies home for electric vehicle batteries, solar panels, wind turbines [and] critical minerals.”

A White House fact sheet, also released Wednesday, pegged new clean energy manufacturing investments since the IRA was signed at $110 billion, including $70 billion in the EV supply chain and $10 billion in solar manufacturing.

Biden also hailed the IRA and IIJA’s $50 billion in investments for energy resilience.

“These laws support important priorities, from addressing historic drought on the Colorado River Basin … [to] responding to coastal erosion [and] sea-level rise in the Gulf of Mexico and helping reduce the effects of extreme heat by investing nearly $1.5 billion to plant trees and expand community parks,” Biden said.

Speaking before the president, Scott Strazik — CEO of GE Vernova, General Electric’s clean energy spinoff — also praised the IRA, saying the law “is working to drive action on climate change, energy security, manufacturing jobs and American competitiveness.”

In Schenectady, N.Y., where GE was founded, “we’ve invested $50 million this year, [and] 200 new union jobs, to create the first 6-MW wind turbine in the U.S.,” Strazik said.

Manchin Missing

Absent from the packed room at the White House — and the president’s speech — was Sen. Joe Manchin (D-W.Va.), who played a critical role in forging final compromises on the law last year. Biden recognized his work at the IRA signing, handing him the pen he used to sign the law and shaking his hand.

A year later, Manchin and the White House are at odds over implementation of the law. The West Virginian has said the IRA is primarily an energy security law, and he has criticized the Biden administration’s efforts to roll it out as a clean energy and climate initiative.

In a statement released Wednesday, Manchin recognized the benefits his state has received from the law, including major investments from long-duration battery startup Form Energy and Berkshire Hathaway subsidiary BHE Renewables.

While praising the law for “putting the interests of Americans and West Virginians first,” he pledged to “push back on those who seek to undermine this significant legislation for their respective political [agendas], and that begins with my unrelenting fight against the Biden administration’s efforts to implement the IRA as a radical climate agenda instead of implementing the IRA that was passed into law.”

When asked about Manchin’s criticism during a press briefing Wednesday, White House senior adviser John Podesta sought to downplay the situation as a matter of interpretation.

“We’re trying to implement it based on what the Congress passed, the law that was written,” Podesta said. “Now he has disagreed a little bit with some of those interpretations, but I think we are operating in good faith to get guidance out as quickly as possible so that these people have the confidence that they can make these long-term, 10-year investments that are included in the act.”

Stronger criticism came from Rep. Cathy McMorris Rodgers (R-Wash.), chair of the House Energy and Commerce Committee, who framed the IRA as “a reckless tax-and-spending spree.”

“One year later, inflation has risen an additional 3%, and people are still paying higher costs to feed their families, keep the lights on and fill up their gas tanks than when President Biden took office,” McMorris Rodgers said. “His disastrous agenda has led innovators to stop research into new, potentially lifesaving treatments and cures, while also increasing our reliance on China.”

But both Podesta and Biden noted that Republican opposition to the law has been tempered by the clean energy investments and jobs the law has brought to their states.

“Once those investments happen, once those jobs are created, once those people are at work in red districts, purple districts, blue districts, it’s very hard to walk away from that,” Podesta said.

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California, Australia Forge Climate Pact

Faced with similar threats from climate change, such as drought, extreme heat and wildfire, California and Australia have made a pact to battle the climate crisis together.

California Gov. Gavin Newsom (D) and former Australian Prime Minister Kevin Rudd, who now serves as Australia’s ambassador to the U.S., gathered with other officials on Tuesday to announce the five-year agreement.

Under a memorandum of understanding signed Tuesday, the officials pledged to work together in areas including zero-emission vehicles, renewable energy development, grid reliability and wildfire resilience.

Like California, Australia has been feeling the impact of wildfires that are becoming more severe as climate change intensifies.

From June 2019 to January 2020, Australian bushfires burned 46 million acres. Emissions from the fires may have contributed to a rare, three-winter string of La Niña weather events, researchers from the National Center for Atmospheric Research recently reported.

“If you’ve been to Australia much, you may have discovered that from time to time it gets a bit dry down there. It gets a bit dry here from time to time, as well,” Rudd said during a news conference in Sacramento on Tuesday. “The natural dryness of so much of California and of Australia is now being compounded by this ever-expanding climate crisis across the world.”

Newsom said California and Australia both are  “on the front lines of the climate crisis.”

“From extreme heat and historic drought to catastrophic wildfires and rising sea levels, the last few years have further crystallized the need for urgent action,” the governor said in a statement.

California has committed to achieving carbon neutrality by 2045, while Australia has set a 2050 net-zero target.

Rudd commended California for its work on electric vehicles, including a ban on sales of gas-powered cars that starts in 2035.

“It’s not just changing California, it’s changing America and changing the world,” Rudd said. “That’s leadership.”

Australia joins California’s growing list of climate partners, which includes Canada, China, New Zealand, Japan and the Netherlands. Earlier this month, California announced a climate partnership with Hainan Province in China. (See Calif. Enters Climate Agreement with China’s Hainan Province.)

In introductory remarks at Tuesday’s event, California Lt. Gov. Eleni Kounalakis (D) said the state’s partnership with Australia is well-timed, coming just a few months before the 2023 Asia-Pacific Economic Cooperation (APEC) CEO Summit. The theme of the event, which will take place in San Francisco in November, is “creating a resilient and sustainable future for all.”

“Today, California and Australia are elevating our joint commitment to combating climate change,” Kounalakis said. “We are signaling our resolve to work together to advance and lead the way to a more sustainable and technologically advanced future.”

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Wash. Raises $62.5M from Cap-and-trade Reserve Auction

Washington’s first cap-and-trade Allowance Price Containment Reserve (APCR) auction raised almost $62.5 million, the state’s Ecology Department said Wednesday.

The auction held last week put up 1,054,809 carbon emissions allowances for bid. Half were offered at a Tier 1 price of $51.90 and the other half at a Tier 2 price of $66.68, which reflects a benchmark set by the open market. The auction was open only to entities that need to cover direct emissions and was closed to financial traders of allowances.

The state was required to hold the cap-and-trade program’s first APCR auction, a mechanism designed to keep carbon prices in check, after prices in the May quarterly auction broke through a soft cap that triggers a requirement to tap the reserve. (See Wash. Auctions Reserve Carbon Allowances to Relieve Price Pressure.)

The list of eligible bidders included eight oil and gasoline companies. The cap-and-trade program has been blamed all summer for the state’s high gasoline prices, hovering around $5 per gallon. Throughout the summer, Washington and California have been swapping first and second place for the nation’s highest gas prices. (See Cap-and-trade Driving up Washington Gasoline Prices, Critics Say.)

Washington does not reveal the bidders’ or winners’ identities or the number of allowances awarded to individual entities to prevent market manipulation.

Washington has raised almost $920 million in the first seven months of the cap-and trade program, with two quarterly auctions left this fiscal year.

During the May 31 auction, the state sold 8.585 million allowances, for a clearing price of $56.01, exceeding the $51.90 soft cap price triggering the APCR auction. Half of those allowances were to be sold for $51.90 per share and half for $66.68 per share.

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Berkeley Lab Reports 25% Increase in Hybrid Solar-Storage Plants

More hybrid power plants are being built in the U.S., the Lawrence Berkeley National Laboratory said Wednesday, and almost all of them combine photovoltaic generation with storage.

In the annual update of its data compilation, Berkeley said the number of hybrid facilities increased 25% in 2022. At the end of the year, it counted 374 hybrid plants with a nameplate capacity greater than 1 MW operating nationwide. Combined capacity was nearly 41 GW of generation and 5.4 GW/15.2 GWh of storage — increases of 15%, 69% and 88%, respectively, from a year earlier.

“Hybrid Power Plants — Status of Operating and Proposed Plants, 2023 Edition” is available on Berkeley’s website; the full presentation includes two case studies.

Also available is “Batteries Included,” a shorter summary of key takeaways from the 2023 report.

Among the findings:

    • Solar-battery hybrids are the most common configuration, accounting for 213 of the total 374 plants and 59 of the 62 added in 2022.
    • The other common configurations are fossil-solar (35), fossil-storage (26) and fossil-hydro (26).
    • Hybrid configurations reflect their primary use cases — the relatively high average storage ratio and duration of solar-storage plants suggests the storage is providing resource capacity and energy arbitrage, while the low average storage ratio and duration of wind-storage plants suggest they are targeting ancillary services markets.
    • Interconnection queue data show continued strong developer interest in hybridization: There were 51% more hybrid plants with 59% more generating capacity in queues nationwide at the end of 2022 than at the end of 2021. In one example, 97% of solar and 45% of wind in the CAISO queue were proposed as hybrids.
    • The Inflation Reduction Act provided standalone storage with access to the investment tax credit for the first time, reducing some of the impetus for hybrid configuration, but that did not take effect until 2023, and Berkeley did not see any impact in the 2022 data.
    • The capacity contribution of hybrids varies but is not equal to the sum of their parts; hybrids often share components such as inverters or interconnections, which can limit their output, as can operational constraints such as charging the storage only from the generator.

Berkeley concluded by saying “more research is needed to understand the full capability of hybrid projects. [Our] ongoing work focuses on themes of hybrid valuation, market rule development and customer resilience opportunities. The end goal of this research is to support private- and public-sector decision-making related to hybrid power deployment.”

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NREL Creates Renewable Energy Materials Database

The National Renewable Energy Laboratory has created a database that quantifies material needs for building each megawatt of new wind and solar power and examines the supplies of those materials.

The Renewable Energy Materials Properties Database is a first-of-its-kind resource, according to Annika Eberle, NREL’s lead researcher on the project.

“The database also allows users to explore the national and global availability of each material and evaluate their potential supply risks,” she said in a news release.

The REMPD compiles extensive information on the vast array of materials needed for latest-generation wind and solar power technology, including country of origin, significant uses, projected availability and physical properties. It does not make predictions, but its data can provide insight into constraints that may develop in the supply chain.

NREL specifically analyzed the future material needs of wind energy development for an accompanying report, “Materials Used in U.S. Wind Energy Technologies: Quantities And Availability for Two Future Scenarios.”

It sounds a cautionary note that has been raised elsewhere: To meet the Biden administration’s lofty goals, the wind energy industry would have to increase installations by a factor of 500% to 1,000%, which could outstrip current global supplies of materials such as carbon fiber, which is used for everything from golf clubs to airplanes.

“We expect demand for carbon fiber to grow rapidly with increasing deployment of wind energy, especially as blades become longer and use more carbon fiber,” Eberle said. “By 2025, our High Deployment scenario projects that new U.S. wind energy installations could use more carbon fiber in a year than is currently produced in the United States.”

A single offshore wind turbine has a calculated need for 12,380 kilograms of carbon fiber.

The authors suggest increased recycling and use of alternative materials to reduce the supply chain pressures shown in the REMPD.

There is also the issue of domestic production: The authors note that 5,000 heavy cast-iron hubs and bedplates are installed each year on American wind farms, and the number is expected to increase to 12,000 to 20,000 annually.

Almost all are imported now, and this growth presents opportunities for U.S. manufacturers.

Details

The REMPD uses a six-tier taxonomy to organize data at the major steps in the wind and solar power supply chain, from raw material to finished material to subassembly to finished component, plus the larger picture of the wind and solar facilities nationwide.

It lists, for example, 159 materials from acetone to zinc needed for a 100-MW solar plant employing cadmium telluride modules versus 168 materials for a similar-sized plant employing crystalline silicon technology. A 7-KW residential or a 200-KW commercial rooftop installation uses vastly smaller quantities of just 124 materials.

The wind database is less complicated, estimating the needs of a single 3.4-MW onshore geared turbine and a single 15-MW offshore direct-drive turbine. The 40 component materials of the onshore turbine weigh in at a combined 488,867 kilograms. The offshore turbine has only 39 component materials, but they weigh a combined 1.34 million kilograms.

In both examples, low-carbon steel is the bulk of the structure: 797,000 kilos for the offshore turbine. The rare earth element terbium is on the opposite end of the scale: less than a gram is calculated for the onshore turbine.

NREL collaborated on the REMPD with the Department of Energy’s Wind Energy Technologies Office and Solar Energy Technologies Office, which funded the project, and with Oak Ridge National Laboratory, Sandia National Laboratories, Lawrence Berkeley National Laboratory and Arizona State University.

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NYC Wants Ride-share Fleet to Go Green by 2030

New York City Mayor Eric Adams on Wednesday announced proposed rules that would require ride-sharing companies’ fleets in the city to go green or be more accessible by 2030.

The Green Rides Initiative proposal would make the city the first metropolis with a set of rules requiring that all vehicles used by companies such as Uber and Lyft be either zero-emission or wheelchair-accessible by the end of the decade.

“When it comes to driving towards sustainable and inclusive transportation alternatives, New York City isn’t just along for the ride; in fact, we are leading the way,” Adams said. “By championing the integration of zero-emission vehicles and wheelchair-accessible transportation, we are cutting dirty emissions and guaranteeing equitable transportation opportunities for every New Yorker.”

The proposal would require 5% of all high-volume for-hire trips be zero-emission or wheelchair-accessible starting in 2024; that requirement would increase by 20% each year after 2026.

Benchmarks for electrifying NYC’s for-hire fleet by 2030 | New York City Taxi and Limousine Commission

Companies would be fined $50 for every 1,000 trips they are below a year’s percentage requirement and have to file a corrective action plan. They would then be fined $500 and be suspended from operating in the city for 30 days if they are found not to be following their prescribed plans.

The proposal is part of Adams’ larger PlaNYC program, a long-term climate plan that, among other things, seeks to ensure every New Yorker lives within 2.5 miles of an electric vehicle charging station by 2035, and electrify school buses and the city’s own fleet. According to the New York City Taxi and Limousine Commission, the 78,000 for-hire vehicles that it has licensed account for about 4% of the city’s vehicle emissions.

Comments on the Green Rides Initiative can be submitted online, and a hearing on the proposal is scheduled for Sept. 20.

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SERC Devotes Webinar to Physical Security Risks, Awareness

With an uptick in physical attacks on electric infrastructure, the Southeastern Electric Reliability Council this week hosted a session on making physical security more bulletproof — literally.

SERC Senior Reliability and Security Adviser Travis Moran said there’s been an uptick over the past few years in ballistic damage to and tampering with substations and transformers.

Moran pointed to a coordinated attack on a substation in Moore County, S.C., in December 2022 that left more than 40,000 customers without power and an attempt on substations in Baltimore, Md., in February by a recently released neo-Nazi felon who previously plotted to bomb a nuclear plant.

“We’ve gone from just cutting wires, copper theft, to now truly targeting our infrastructure to have significant impacts,” Moran said during SERC’s Aug. 15 webinar, titled “Policy Considerations for Enhancing Physical Security of the Grid.”

Moran said 2013’s Metcalf, Calif., incident, where unknown suspects cut phone cables and opened gunfire on a substation, represented a tipping point showing that the “threat posture had changed from what we historically faced.”

“It’s important to understand where we are now, and how we got here, where we came from,” he said.

Before then, Moran said criminal activity at substations was limited to “garden variety” vandalism, break-ins and theft.

Moran said in recent years, the loss of megawatts in the U.S. due to physical attacks far outnumbers the outages that cyberattacks cause, though cyber has a “larger attack surface.” He said in 2021, 92 physical attacks resulted in utilities losing 145 MW, affecting more than 56,000 customers. In contrast, 2022 contained 163 physical attacks that took out almost 7.5 GW, affecting almost 94,000 customers.

Moran said NERC’s CIP-014-3 standard for physical security is only a “baseline,” and he encouraged companies to go above and beyond.

He urged attendees to test vulnerabilities and identify their threats, unacceptable consequences and their “diamonds,” or key design elements their systems cannot afford to lose. He said the “diamonds” require more layers of physical protection.

“I don’t care if you’re an investor, a muni, a co-op, you all have something to lose,” he told attendees.

Moran also said it’s worth studying the motivations behind physical attacks, including neo-Nazi agendas, anti-authority and anti-capitalism philosophies, monetary focuses and environmental ideologies.

“Our adversaries are learning. And that’s a key variable that we always have to keep in mind: They’re gathering intelligence,” he said.

Moran said attackers are becoming increasingly aware of weak points on equipment to target with bullets, including the cooling fans of transformers. He said a shooter can be a fair distance away and still attack effectively.

Moran also said individuals are becoming more sophisticated with drone attacks.

“Previously they were kind of an anecdotal threat,” he said.

Moran said when designing substations and transformers, utilities should bring in physical security experts as early as possible. He said utilities should consider the proximity of critical equipment to fence lines and which directions equipment faces. Once operational, utilities should engage with trusted partners regularly to continue testing their protection systems and improving their physical security postures, he said.

Moran said utilities should be aware that perpetrators often prefer to execute attacks to coincide with mass gatherings, including sporting events and political rallies. He also said attackers will make attempts during extreme weather events, knowing that outages in heat waves and winter storms will be an “opportunity multiplier” to cause maximum harm.

“It’s unfortunate to talk about these kinds of things, but that’s unfortunately where we are in this day and age,” he said.

Moran said companies should remember that electricity is a “life-sustaining force” that is integral to banking, water, food, hospital and transportation systems.