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November 15, 2024

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Overheard at NARUC Summer Policy Summit 2023

AUSTIN, Texas — The National Association of Regulatory Utility Commissioners’ annual Summer Policy Summit attracted more than 1,000 state and federal regulators and their staffs; industry representatives; consumer advocates; and other stakeholders July 16-19 for discussions on understanding and preparing for the grid challenges that lie ahead.

NERC’s recent summer reliability assessment lent considerable fodder to the discussions, with its warning that extreme weather, plant retirements and transmission outages have made supply shortfalls more likely across much of the U.S. The report also stressed the need to maintain and expand a dispatchable baseload generation fleet to keep pace with the higher demands that electrification and climate change are placing on the grid. (See West, Texas, Midwest at Risk of Summer Shortfalls, NERC Says.)

Attendees network during a break in NARUC’s Summer Policy Summit. | © RTO Insider LLC

Speaking on a panel discussing the reliability challenges, Stan Connally, Southern Co.’s executive vice president of operations, said shrinking reserve margins are complicating the task of balancing clean energy with affordability.

“Frankly, I think one of the risks as we move forward here is we let those priorities get out of balance,” he said. “It’s just important that we continue having these reliability conversations, because at the end of the day, and in these very, very extreme conditions, our customers need us to have the lights on. Air conditioning matters, right?

“Resource adequacy is a big deal. Shrinking reserve margins are something we have to pay attention to around resource adequacy,” Connally added. “We have an aging fleet. We also have a growing solar base. … Mixing that all together to ensure resource adequacy for the long term has to be center stage of our planning.”

Fellow panelist Stacey Doré, Vistra’s chief strategy and sustainability officer, said her company’s diversified fleet gives it a unique advantage in achieving balance between reliability, affordability and sustainability.

“We do see near-term reliability risks because we think that the projections show that thermal generation is going to be retiring at a faster pace than we can make up for with other assets in the long term,” she said. “We’re all trying to get to the place where we have enough carbon-free, reliable generation to replace those thermal assets … but the pace at which that is happening is not keeping up with the pace at which thermal assets are retiring.”

Southern Co.’s Stan Connally shares his thoughts on shrinking reserve margins as Vistra’s Stacey Doré listens. | © RTO Insider LLC

SPP COO Lanny Nickell said the transition to renewables and decarbonization will continue to take place, “whether or not you like it.” With clean energy goals set for 2050 and progress to be made by 2030, he said he used to be more worried about 2030 than 2050.

“Unfortunately, over the last several months, I’m no longer as worried about 2030 as I am about right now,” Nickell said. “Our analysis has indicated there’s a growing amount of risk that we can’t sustain. We’ve seen about 8,000 MW of thermal generation retired over the last seven, eight years. In that same time frame, we’ve seen about 24,000 MW of wind generation added. That sounds like a pretty good tradeoff. It hasn’t been, and our loss-of-load expectation studies that we have to perform every other year are indicating an increased risk associated with that transition.

“It may sound like we’re three Chicken Littles up here trying to scare everybody, but there are solutions. It’s just a lot of these solutions will take time to see the full effect,” he added.

Nickell reminded the audience that transmission is “an important tool in the toolkit” and offered resilience as an example. Instead of valuing transmission for its reliability and production cost savings through reduced congestion, he said, grid operators also should realize the importance of shipping energy across their seams.

“After Winter Storm Uri, we came to realize that resilience has got to be one of those measures,” he said, noting that when the storm took thermal resources offline in February 2021, SPP was able to meet 14% of its demand with imports from MISO and PJM. “We were importing on a transmission system that’s never seen this much energy flow across it … because we had strong interconnections throughout much of the East and to the West. That’s the value of resilience. It’s like insurance. You don’t really want to have to use it, but man, you’re thankful when you have it.”

Valuing Energy Efficiency

Speaking on a panel debating extreme weather’s reliability implications, former FERC and Texas regulatory staffer Alison Silverstein pointed out that energy efficiency doesn’t need to be accredited for effective load-carrying capability (ELCC) “because it doesn’t break down.”

She said that with an “intentional strategic demand response,” the industry will be able to take advantage of two areas that have “important synergistic effects” for the wind and solar fleet.

“With the right choices and energy efficiency and demand response, you are bringing down the peak overall,” Silverstein said. “With the amount that you need to fill in the evening as the wind is ramping up and the solar is dropping, you have less of a gap to fill out every hour. The more we can do to make our homes and buildings more energy efficient, the less we have to do in terms of that kind of ramping and the less vulnerable we are to the ELCC for this kind of thorough plan.”

Alison Silverstein | © RTO Insider LLC

Texas established the nation’s first energy efficiency resource standard (EERS) in 1999 by requiring utilities to achieve a specified amount of energy efficiency savings annually. It has since been leapfrogged by 26 other states and now has the weakest EERS in the country, according to a 2021 white paper by the American Council for an Energy-Efficient Economy.

Silverstein posited that the state’s roughly 4 million poorly insulated homes, more than a third of the total stock, is one reason ERCOT has been able to meet record demand this summer. (See ERCOT Demand Exceeds 82 GW for 1st Time.)

“It’s because 45% of Texans are low income and energy insecure. They are setting their thermostats at unsafe levels,” she said. “They are doing voluntary conservation of electricity, not because they’re trying to be good public citizens for the reliability of the grid, but because they can’t afford to consume enough electricity to stay comfortable. If they were able to consume more electricity, our demand would be significantly higher, and [ERCOT CEO] Pablo [Vegas] is going to be pacing the back of the control room.”

Remembering the 2003 Blackout

NARUC President Michael Caron, a commissioner on the Connecticut Public Utilities Regulatory Authority, kicked off the summit by moderating a panel marking the 20-year anniversary of the 2003 Northeast Blackout. The memories of that day still linger with the panelists.

“I think about this every day and before I go to bed at night, which explains the bags [under my eyes]. It was terrifying,” NERC CEO Jim Robb said. “I never thought I would be in the role that I am today.”

Texas Public Utility Commissioner Jimmy Glotfelty was on vacation camping with his family and several others in New Mexico, having just helped stand up an electricity office in the U.S. Department of Energy. Like other government officials, he left D.C. for much of the month. Fortunately, he had access to the camp site’s “communications center,” a closet with one phone and a fax machine.

“I spent the next two and a half days in that phone booth on phone calls with folks from NERC, our [National] Labs, folks from the White House and in Canada, trying to figure out how we would do this investigation, which we’ve never done before and had no real understanding of how to jumpstart it,” Glotfelty said. “We found the path forward that really started the Monday after the blackout, sending teams out to the utilities, out to the ISOs, to NERC, and put a plan together to really study what happened. So, we had all sorts of phone calls back and forth, and it was an interesting place to be for the biggest blackout in North American history.”

Suedeen Kelly was in FERC’s library the day of the blackout preparing for a Senate hearing on her nomination to be a commissioner.

“You felt disbelief at first and then shock and horror, and then a realization that I was soon to join an institution that was amazingly well prepared to try and do something about this,” she said.

An interim report identified the cause — a software bug that left operators unaware they had to shed load after transmission lines drooping into vegetation caused the initial outage — but did not make any recommendations. That came early in 2004 from an independent commission formed by President George W. Bush and Canadian Prime Minister Jean Chrétien.

The report team ran into a late roadblock when the Canadians said the final report had to be translated into French.

“‘How long will that take?’” Glotfelty remembered asking. “‘Three weeks.’ We said, ‘No way.’ We ended up getting support from the State Department, which translated the report in two days.”

The report and the Energy Policy Act of 2005 led to numerous changes in the industry. Most important, it gave greater authority to NERC to enforce standards that previously had been treated as guidelines. It also led to changes in how operators handled transmission outages.

“The greatest thing we did was shed load,” Glotfelty said, referring to ERCOT’s response during the 2021 winter storm that almost brought the Texas grid to its knees. “What happened in 2003 was the wrong action. System operators were scared to shed load. They figured they would get fired or their companies would get beat up by their regulators.

“In Texas, we did that. People still got fired, but we saved the system,” he added. “We saved 30 days of economic and human suffering by shedding load and making sure the transmission system stayed viable. So that was really an important understanding from the 2003 blackout.”

Asked whether the country might see another blackout like the one 20 years ago, Robb said, “I feel generally quite good about how the risks of 20 years ago were addressed.” Indeed, his organization’s recent State of Reliability report found that the North American bulk power system generally remains highly reliable and resilient.

“If you look at the performance of the electric grid as we define it from a reliability perspective, we have made substantial improvements, but the risk profile continues to grow,” Robb added, pointing to renewables’ growing share of the fuel mix. “We are working with our partners — NARUC, the gas sector, the technology sector — to try to figure out how we can solve these issues that nobody can solve with an edict. There’s been a lot of evolution of the model that was created, but I think we should all be extraordinarily [confident].”

Will EPA Rule Accelerate Change?

EPA’s recent proposed regulations to reduce carbon emissions from fossil-fired power plants under Section 111 of the Clean Air Act would set nationwide standards on plants based on whether they are new or existing, their fuel type, frequency of usage, capacity and how long they plan to operate. (See EPA Proposes New Emissions Standards for Power Plants.)

Naturally, the proposal has raised concerns within the industry.

“We are the reliability watchdogs for North America, and we don’t dissect the particularities of this rule,” said NERC’s Fritz Hirst, director of legislative and regulatory affairs. He compared his agency to the Night’s Watch, which protects the main setting of the television series “Game of Thrones” but holds no allegiance to any of the show’s feuding kings and lords.

“Our role was to provide this common good, but I think it is kind of obvious to say that this rule will continue to accelerate the pace of change,” Hirst said. “In NERC’s view, managing the pace of change is the central challenge for reliability.”

In the short term, natural gas will continue to be a primary fuel source, GridLab Executive Director Ric O’Connell said.

“Natural gas just a couple of decades ago was kind of a hobby fuel, right? It was the summer-peaking fuel,” he said. “Natural gas has really come from kind of the sidelines … now it is 40% of our electric generation. The electric system is the largest user of the gas system, and we haven’t really changed the way we contract and think about delivery of gas. It’s now a year-round baseload fuel, and in the winter, it’s really competing with other uses like heating.”

Ric O’Connell, GridLab | © RTO Insider LLC

Emily Sanford Fisher, Edison Electric Institute’s executive vice president of clean energy, said with coal fuel’s use down to less than 20% of the nation’s fuel mix, non-emitting resources (renewables and nuclear) account for more than 40% of electricity consumption.

“The industry is in a different spot,” Fisher said, noting that about 50 of EEI’s members have made voluntary commitments to reduce their emissions to zero or net zero, albeit “not on the time frame that EPA puts out.”

“That means that we are generally in agreement about where the industry is headed, and this is really a question about pace and timing and the role of technology,” Fisher said. “Interestingly, all of the conversation in 2014-2015 was about coal. All of the conversation today is really about the role of natural gas, and that reflects this change in our generation mix. You can see from the rule that EPA is pretty concerned about our reliance on gas, and we’d like to make sure that it puts some bumpers around how much gas generation remains a part of our mix.”

Time is Now for Nuclear

One month after taking the stage during Edison Electric Institute’s thought leadership forum to promote nuclear energy’s role in a carbon-free future, Julie Kozeracki, a senior adviser with the Department of Energy’s Loan Programs Office, returned to Austin to highlight advanced nuclear reactors. (See “Nuclear Needs a Breakthrough,” Overheard at EEI 2023.)

Julie Kozeracki, DOE | © RTO Insider LLC

Kozeracki said she has been leading a DOE initiative on nuclear commercialization that has resulted in a report, “Pathways to Commercial Liftoff: Advanced Nuclear.” It says advanced nuclear technologies, such as Gen III+ reactors similar to conventional generators and Gen IV reactors that use novel fuels, provide a “proven option” to supply the 550 to 770 GW of additional clean, firm capacity necessary to reach net zero.

“We see there being a need for 200 GW of new nuclear capacity, in addition to the roughly 100 GW we have operating today,” Kozeracki said. “That’s because in any decarbonization scenario, we see there being a need for upwards of 700 or 800 GW of clean, firm capacity. Because regardless of whether you build a ton of renewables or a crazy amount of renewables, you need some firm capacity to help balance the intermittency of renewable generation. And nuclear is one of the only options proven at scale.”

She put in a plug for small modular reactors, saying they can provide more certainty of hitting cost targets and likely will play an important role in the early scale-up. Kozeracki said commitments for new nuclear are needed as soon as possible.

“The time to start on that was yesterday,” she said. “The choices in front of us are not between new nuclear, which could feel risky or expensive, because your other options are also going to be risky and expensive. It’s really important to recognize that nuclear has a vital role to play in getting to decarbonization at scale, and anything we can do to start those conversations and those decisions sooner is going to be really critical for getting us on the path there.

“Everyone keeps saying that they want to be fourth, and they would like someone else to go first, second or third. But you can’t have a fourth reactor if folks don’t sign up for one, two and three.”

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Mixed Views on Impact of Arizona Climate Alliance Membership

Arizona’s decision to join the U.S. Climate Alliance could rev the state’s clean energy economy, some observers said, but others warned that politics could get in the way.

Gov. Katie Hobbs (D) announced this month that Arizona has joined the Alliance, a coalition that includes 23 states, Guam and Puerto Rico. Alliance members promise to pursue policies to reduce climate pollution and promote clean energy deployment.

“Together, we are creating green jobs and businesses, ensuring clean air and water for Arizonans, lowering energy costs and preparing more effectively for a changing climate,” Hobbs said in announcing the move.

Hobbs’ announcement came around the time Gov. Joe Lombardo withdrew Nevada from the Alliance, citing conflicts with the state’s policy of developing a diverse energy portfolio that includes natural gas. (See Nevada Exits US Climate Alliance.)

Michael Barrio, a senior policy principal at Advanced Energy United, highlighted the potential economic benefits of Alliance membership for Arizona. AEU is a business association aimed at achieving 100% clean energy in the U.S.

By joining the Alliance, “we’re really opening the doors to investment,” Barrio told NetZero Insider.

Businesses are attracted to states with a stable and predictable clean energy framework, Barrio said. He noted that a growing number of businesses — including large companies such as Meta — are making clean energy commitments.

“Arizona is signaling that this is a state where those kinds of commitments can be fulfilled,” Barrio said.

Attorney Court Rich, director of the Regulatory and Renewable Energy Department at Scottsdale-based Rose Law Group, said clean energy and related technology represent a “massive” economic opportunity for Arizona. Hobbs has sent a strong message of support by joining the Alliance, Rich said.

“But given state politics, and a GOP-controlled legislature and utility commission, we need everyone on board to make sure Arizona maximizes its potential to be a leader in the clean energy economy,” Rich told NetZero Insider.

“At the end of the day, I would be surprised if joining the Alliance has any impact on Arizona’s actions on emissions,” he added.

Arizona already is making clean energy-related economic progress. A report this year from Climate Power, a strategic communications organization, found that investments in clean energy projects led to 12,720 jobs in Arizona from the time the Inflation Reduction Act became law in August 2022 through March 2023.

Among 191 new clean energy projects nationwide, the report pointed to LG Energy Solution’s plans to build a $5.5 billion battery manufacturing complex in Queen Creek, Ariz., where it will make batteries for EVs and energy storage systems.

States Working Together

U.S. Climate Alliance members take action through steps such as adopting climate action plans, setting zero-emission vehicle standards and developing building performance standards. Hobbs’ office didn’t respond to requests for details on the administration’s next steps regarding climate change.

Diane Brown, executive director of the Arizona Public Interest Research Group, said Hobbs and her newly created Office of Resiliency have “hit the ground running” in terms of pursuing federal funds for clean transportation and clean energy and working with a wide array of stakeholders to address climate change and its impacts.

Membership in the U.S. Climate Alliance will give Arizona a chance to collaborate with other states on best climate practices, Brown said.

“The result of developing and implementing strong climate change mitigation policies will not only reduce climate pollution, but can save consumers money, protect air quality and promote public health,” Brown told NetZero Insider.

Beyond Pledges

Another commitment from Alliance states is to reduce net greenhouse gas emissions by at least 26% by 2025 and 50% by 2030, as compared to 2005 levels, and reach net zero by 2050.

A report this month from the Environmental Defense Fund (EDF) looked at the impact on national climate progress of 24 Climate Alliance states hitting their 2025 and 2030 targets.

Hitting the state targets would reduce by 43% the national emissions gap — the difference between projected emissions and a Biden administration goal to cut nationwide emissions by at least 50% by 2030, the report found.

In updated figures provided to NetZero Insider last week, factoring in Arizona’s membership in the U.S. Climate Alliance and Nevada’s withdrawal, EDF found that the national emissions gap would shrink by 44% if states reach their targets.

But many states are struggling to meet their commitments, the report found. The 24 states in the report are on track to collectively reduce net emissions by 20 to 23% by 2025, short of the 26% target, and by 27 to 39% in 2030, compared to the 50% reduction target.

Pam Kiely, EDF’s associate vice president for U.S. climate, said governors “must drastically step up ambitious and comprehensive policies to cut pollution in line with their goals.” And the Inflation Reduction Act gives them an opportunity to do so, Kiely said.

“Generating that collective impact requires moving beyond just pledges — governors have to deliver on their promises,” Kiely said.

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Maine Blows Past Heat Pump Installation Target

The state most heavily dependent on home heating oil is making significant strides in its campaign to get electric heat pumps in more homes.

Maine Gov. Janet Mills (D) said Friday that 104,000 of the systems have been installed with help from a series of initiatives begun after she took office in 2019.

The goal had been 100,000 by 2025, so she set a new goal: 175,000 additional heat pumps by 2027. Success would mean a significant portion of the state’s 750,000 housing units had at least partially decarbonized.

Maine is a state that would seem at once ideally suited and highly challenging for heat pumps. Few areas have natural gas distribution infrastructure and only 1 in 13 households use it as the primary heating fuel, according to the U.S. Energy Information Administration. As a result, about 60% of Mainers heat with oil as of September 2022, more than any other state.

Air-source heat pumps are less expensive to operate than oil furnaces and can have a lesser impact on the environment. But there is some lingering skepticism in the public mind about their efficacy during cold snaps, and Maine is one of the coldest states in the nation.

The Maine Energy Marketers Association, whose members sell all manner of fuels, is trying to ensure the public is aware of the potential shortcomings of heat pump technology.

However, state residents seem to be voting with their pocketbooks: The number of heat pumps installed statewide has climbed from about 40,000 in 2019 to roughly 145,000 now.

Mills’ office said Friday that heat pump rebates through Efficiency Maine and a low-income heat pump program at MaineHousing have been instrumental in getting the technology installed in the state’s residential and commercial structures.

Efficiency Maine pitches federal tax credits to accompany the state rebates for installation. Together with savings on operating costs, a homeowner can recoup the purchase cost in as little four to six years, the program’s website says, depending on whether they qualify for a low- and moderate-income adder.

Efficiency Maine does, however, warn that a fuel-burning backup system is needed in temperatures below minus 15 degrees.

Legislation Mills signed in 2019 to encourage and subsidize property owner adoption of heat pumps was accompanied by another important effort: development of a workforce to install all those heat pumps.

The state’s community college system expanded its heat pump training courses and has trained 558 technicians to date.

The heat pump campaign is part of a larger effort by Maine to fight climate change. Mills last year signed a law setting the goal for carbon neutrality as 2045 and this year proposed moving the 100% clean energy target date from 2050 to 2040.

Clean energy is important to the climate impact of heat pumps. As the Maine Energy Marketers Association points out, heat pumps are not as green as they seem if the electricity that powers them comes from burning carbon.

White House National Climate Adviser Ali Zaidi joined Mills for her announcement Friday.

“Maine is paving the way for states across the country seeking to build a clean energy future that protects our climate and creates good-paying jobs for all Americans,” he said in a news release.

Mills added: “Our transition to heat pumps is creating good-paying jobs, curbing our reliance on fossil fuels and cutting costs for Maine families, all while making them more comfortable in their homes — a hat trick for our state.”

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NYDPS Report Shows State Emissions Down Nearly 50M MT

New York took strong first steps to comply with climate and energy legislation mandating that it reduce its emissions and decarbonize its economy, according to a preliminary review released last week (22-M-0149).

The Department of Public Service gave an upbeat impression in its first annual progress report on New York’s compliance with the Climate Leadership and Community Protection Act of 2019.

“New York State has invested a great deal in its initial efforts to realize the clean energy growth and emissions reduction goals of the CLCPA,” reads the DPS’s conclusion.

Overall emissions reductions | NYDPS

According to the report, New York’s overall emissions production was reduced by 49,499,299 metric tons of carbon dioxide from 2020 to 2022. Mostly this was due to fossil fuel displacement, but it is increasingly being offset by EVs.

The New York State Energy Research and Development Authority during this time collected $1,871,922,708 through its renewable energy credit programs, and 95,937,409 MWh of clean energy was produced from load-serving entities procuring RECs, which contractually obligate generators to deliver certain amounts of renewable energy.

Statewide energy benefits | NYDPS

These are positive signs for New York, since the CLCPA is ambitious: 70% renewable electricity by 2030, 100% zero-emission electricity by 2040 and net-zero emissions statewide by 2050. The policy also mandates the state procure at least 6 GW of solar energy by 2025, 3 GW of storage resources by 2030 and 9 GW of offshore wind by 2035.

The DPS noted its results do not yet include Tier 4 or OSW contracts, known as ORECs, because these projects are not in commercial service but should bring even greater benefits once operational. (See OSW Developers Seeking More Money from New York. See NYSERDA Seeks 1-Year Delay for Tier 4 RECs.)

The report added that the CLCPA necessitated “an extensive restructuring of the existing grid,” which has driven renewed investment into both upgrading antiquated lines and adding more resilient lines that can tolerate greater voltage conditions from more advanced technologies.

The DPS also highlighted New York’s initiative to decarbonize not only the larger barriers to net zero, but also other critical sectors like transportation and housing, and the DPS commended the state’s actions to promote disadvantaged communities, such as obligating them to receive at least 35% of all decarbonization investments. (See NY Climate Justice Panel Sets Disadvantaged Community Criteria.)

Despite this relatively rosy assessment, New York risks not meeting its goals, given how NYISO reports predict future reliability shortfalls that may require emissions-producing peaker plants to operate past their expected retirement. (See NYC to Fall 446 MW Short for 2025, NYISO Reports.)

These reservations were seen at the DPS’s monthly meeting, during which the inaugural report was delivered and discussed, and several commissioners voiced concern about future costs and reliability. (See “CLCPA Update,” Energy Transition Costs Give NY Utility Commissioners Pause.)

The DPS report calls on state agencies, including itself, to be “more transparent to the public” about its CLCPA compliance to help New York stay on track to achieve a decarbonized economy by 2050. The agency promised to improve its scoring guidance and data reporting criteria (14-M-0094).

Clean Energy Progress

The DPS’s first report card on New York’s CLCPA compliance had useful metrics to show the state’s progress:

    • 66% of New York’s projected 2030 electricity is covered by renewable energy projects that already are operating, contracted or awarded.
    • 46% reduction in statewide emissions produced from electricity and 7% reduction in gross emissions between 1990 and 2019, according to the Department of Environmental Conservation.
    • 1% of the renewable energy standard obligations were met by LSEs, while 99.8% of LSEs under PSC jurisdiction met their RES obligations in 2021 (15-E-0302).
    • 5% of the zero energy credit obligations were met by LSEs, while 99.8% of LSEs under PSC jurisdiction met their ZEC obligations in 2021 (15-E-0302).
    • 5,999 MW of solar resources are either committed or completed as of November 2022, according to the NY-Sun midpoint review, and the NY-Sun program is on track to spend $200 million on projects by 2025 (21-E-0629).
    • 1,301 MW of energy storage resources has been awarded or contracted as of October 2022, which represents 87% of the 2025 target (18-E-0130).
    • ~12,000 MW of proposed ESRs are circulating in New York’s distribution-level or wholesale-level interconnection queues.
    • 144,037 EVs were registered in New York as of May 2023, while 8,002 level two and 1,215 direct current fast charging ports were serving the state’s fleet, according to EValuateNY.
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MISO Preps for Heat Wave, Anticipates Annual Demand Peak

MISO has enacted conservative operations orders, a hot weather alert and a capacity advisory for its Midwest region ahead of the season’s first widespread heat wave set to bake much of the U.S. this week.

The grid operator said a combination of hot weather and load forecast uncertainty is forcing a conservative operations declaration Tuesday through Friday for MISO Midwest. The capacity advisory is effective beginning Wednesday “until further notice,” per MISO.

The National Weather Service anticipates dangerous heat that has been simmering in the West, Texas and Florida will expand this week into the eastern two-thirds of the country, starting in the north-central states and Plains.

MISO has asked its generation and transmission owners to consider revoking or deferring maintenance outages. It also has asked generation owners to notify it of any fuel restrictions and environmental limitations of equipment. MISO said members should be prepared to enter maximum generation emergency procedures, which involve calling on load-modifying resources.

Spokesperson Brandon Morris said MISO and members are preparing for the extreme heat, which could drive 2023’s annual peak demand in the footprint.

“The potential for higher-than-normal demand and tight operating conditions could lead to a system peak for the year. MISO issued alerts and advisories in anticipation of the heat wave to provide situational awareness and notify our members’ utilities to prepare in case additional actions are needed to ensure reliability,” Morris said in an emailed statement to RTO Insider. “We are coordinating with our neighboring grid operators who expect similar conditions. Because of our large, diverse footprint, MISO has several options to obtain power and send it to where it is needed.”

Ahead of the season, MISO predicted July would hold its greatest chance of enlisting the help of its load-modifying resources and leaning on neighbors for exports during blistering temperatures. (See MISO: Little Firm Capacity to Spare This Summer.)

MISO last issued conservative operations instructions in late June, when it struck a rough patch of storms and hot temperatures that also spawned capacity advisories and hot weather and severe weather alerts June 22-30. The RTO also issued a hot weather alert July 19-20 for much of its South region.

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SPP REAL Team Endorses Winter Resource Requirement

AUSTIN, Texas — Texas commissioner Will McAdams, chair of SPP’s Resource and Energy Adequacy Leadership (REAL) Team, set the tone from the outset when he shed his blazer and rolled up his sleeves as the group gathered for its meeting Wednesday.

“It’s July in Texas. Let’s get started,” he said.

For the next nine hours of what McAdams called a “crusher” of a meeting, the REAL Team discussed issues ranging from flexibility and ramp associated with capacity obligations to maintenance outages and their effect on capacity obligations. A central theme emerged around how SPP compensates load-responsible entities for availability or penalizes them for lack of availability during critical hours.

“It’s a lot of ships that we hope are moving in the same direction now, but it’s a lot to coordinate,” McAdams told fellow commissioners during an open meeting the following day.

The team met its first objective when it endorsed a winter resource adequacy requirement (RAR) approved recently by the RTO’s Markets and Operations Policy Committee. The revision request (RR549) will go before SPP’s state regulators and its Board of Directors this week for final consideration. (See “Members Endorse Winter Resource Adequacy Requirement for 2024-25,” SPP Markets and Operations Policy Committee Briefs: July 10-11, 2023.)

The measure applies the same level of validation, study and assessment requirements to the winter season (December through March) that is applied to the summer season, including a deficiency payment for capacity shortfalls. It also assigns an annual deficiency payment to prevent duplicate payments for the same capacity within an annual timeframe.

RR549 is not without its detractors. It barely met MOPC’s approval threshold and cleared the REAL Team with two votes to spare, 9-5. Members removed one of two revisions added during the MOPC discussion over confidentiality concerns.

The measure is effective for the 2024/25 winter season (December through March).

“It was a hairy deal,” McAdams told the Texas Public Utility Commission. “It’s a real shootout. Just trying to provide the mechanisms that ensure resource adequacy is not an easy thing. These are not easy decisions.”

SPP’s board and state regulators created the REAL Team, comprised of 14 independent directors, members, and regulators and their staff, earlier this year. The team has been meeting every three weeks since May. (See SPP’s REAL Team Swings Into Action.)

“I think the REAL Team is a bit of a fusion center,” McAdams told RTO Insider after the team’s first in-person meeting in May. “It’s bringing together corporate members, components of the Members Committee, the stakeholder components of SPP together with [Regional State Committee] leadership as well as board leadership … so that topics can be flagged and, frankly, polled to a degree in terms of resistance to certain staff recommendations and or support.”

The team has created sub-groups focused on resource adequacy, markets and operations. They will lean heavily on the Supply Adequacy Working Group (SAWG), which has primary responsibility for nine of the 11 objectives assigned to the REAL Team.

Its next milestone comes in October, when it plans to consider a ramping capacity requirement, begin addressing the footprint’s need for reliability attributes in the resource mix and endorse tariff changes — RR554 and RR568, respectively — that codify performance-based accreditation (PBA) and effective load carrying capacity (ELCC) policies.

The SAWG is developing both tariff revisions. It has created limitations for catastrophic exemptions that apply to all resource types that will sunset after 10 years of historical data from the units. The working group also has simplified the ELCC tiers by using a two-tiered approach with firm and non-firm transmission service.

More important, the SAWG has prepared a system methodology for upcoming loss-of-load expectation and ELCC studies that evaluates the collective reliability contribution of all ELCC resources to ensure they are correctly accredited.

SPP is responding to FERC’s recent order admitting it had mistakenly approved the RTO’s proposal to use an ELCC methodology to accredit wind and solar resources based on historical performance. The commission has granted renewable developers a rehearing of its original order. (See FERC Grants Rehearing of SPP Capacity Accreditation Proposal.)

The grid operator’s Market Monitoring Unit said it had equity and accountability concerns over the PBA and ELCC. It recommended measuring individual performance in the PBA process against the top 3% net peak load and including all outages, whether forced maintenance or out-of-management control, in the accreditation processes.

The MMU offered two recommendations it said would improve reliability that left one commission staffer shaking his head: the PBA measurement against the top 3% net load and implementing a true-up process at the end of each season.

Keith Collins, vice president of market monitoring, shared an event his team picked up just before July 4, when SPP had issued a resource advisory and then a conservative operations call. He said the MMU became aware of several hundred megawatts of resources, accredited for the summer, that were on outages because of staffing issues.

“They were aware … that whatever they were going to do was going to be accounted for in performance-based accreditation, and they did it anyway,” Collins said. “If we want to think of the incentives and what we’re doing to keep people from making those decisions and contributing to a reliable system, particularly when we need it the most, then we’re not there yet — because they did it anyway.”

Keith Collins explains Market Monitoring Unit’s view on accreditation proposals. | © RTO Insider LLC

SPP’s continued integration of renewable resources over conventional or thermal resources has created operational uncertainty and shortened the staff’s ability to commit resources, according to C.J. Brown, director of system operations. On Sunday, the RTO issued a resource advisory because of high loads, load and variable energy forecast uncertainty, and resource outages; it is at least the sixth resource of conservative operations advisory SPP had called since April.

“Those are very challenging and stressful situations,” he said. “You feel like every one thing you give up could put you into a situation where you’re not able to cover a certain percentage of uncertainty. We have to do that leading up to and including real time, and that starts as much as seven days out. Typically, about four days out is our longest lead time when a decision has to be made, but that’s just a continual process these days.”

“Two years ago, we might have made that decision two or three times a year,” Brown added. “Now it seems like it’s every other week.”

To maintain current levels of capacity until sufficient resource adequacy measures are in place, staff are developing policies — likely including some form of system support resource or reliability must-run contracts used by other grid operators — that “strongly encourage” generation owners to reconsider and postpone retirements. Based on utilities’ integrated resource plans and information gleaned through the transmission process, SPP expects 6.5 GW of gas- and coal-fired resources to retire by 2030.

The problem is compounded by hints of reluctance from renewable developers about investing in an RTO where conventional resources are retained.

“What we’re hearing is some of the recommendations and activities we’re making in the SAWG space and in the REAL space might be shifting renewables to other more profitable regions,” Casey Cathey, senior director of grid asset utilization, told the REAL Team. “Are we defining the requirements at a razor’s edge to where we’re just maintaining the fleet and barely improving? I think we need more markets, we need more carrots to be able to better optimize over a longer time horizon so the LREs can kind of appreciate what kind of supply we actually better recognize … we want to make sure we’re sending the right signal that if we are retaining our conventional fleet, that we have a path forward, because right now it seems like there’s a whipsaw.”

SPP’s generator interconnection dashboard indicates solar resources account for 43% of the projects in the GI queue (45.6 GW of 105.5 GW), followed closely by wind (26.1 GW, 24.8%) and battery storage (19.9 GW, 18.8%). Cathey said solar requests exceeded those for wind for the first time earlier this year.

“We can’t wait [for the solar]. We’ve had 250 megawatts of installed solar for a long time, but we have just not seen that build,” he said. “We’ve been thinking for about six to seven years that this might be our next frontier. Wind is highly volatile, it can be helpful, but a lot of times when wind winds down, solar’s actually doing pretty good.”

Cathey said the potential 90 GW of solar, wind and batteries in the queue doesn’t give him “a lot of comfort,” however.

“If we installed all gigawatts of wind, solar and batteries and we also retired a good portion of our conventionals, we would still have C.J. describing some slides of some conservative operations, and so we need to be balanced here,” he said. “Hopefully, a lot of this gets built but we also need to make sure we’re sending the right signal to either keep resources, conventionals, online for a period of time until another technology can take over.”

RA Forum Draws Industry Interest

The REAL Team will hold its next in-person meeting Sept. 8 in Dallas, the day after SPP hosts a Resource Adequacy Summit at DFW International Airport.

What started as a meeting limited to 75 attendees has blown up into an industry event that has drawn the interest of at least two FERC commissioners, according to organizers. NERC’s and EPRI’s CEOs, Jim Robb and Arshad Mansoor, respectively, have accepted invitations.

“There’s heavy interest nationally to provide forums where the reliability standard concept can be discussed on a national basis, what that involves and what defines resource adequacy, not just within ISOs but regionally,” McAdams said.

SPP has extended invitations to its neighbors, with MISO already accepting. ERCOT also has been invited to attend.

Even without ERCOT, Texas will have a heavy presence. McAdams said PUC staff will attend and energy consulting firm E3 will discuss valuing availability. E3 proposed an LSE reliability obligation construct and several other market designs for the Texas grid operator following the disastrous and deadly 2021 winter storm.

SPP has secured a larger meeting space than originally planned to handle the increased attendance.

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NYISO Operating Committee Briefs: July 22, 2023

NYISO updated the Operating Committee on Thursday that 89 MW of nameplate behind-the-meter solar was added onto the grid in June. The month’s peak load was 22,867 MW and the minimum was 11,999 MW.

Mark Younger, president of Hudson Energy Economics, referred to the growing megawatts of energy storage resources in New York and asked what percentage of them can sell capacity resource interconnection service. (See “May Operations Report,” NYISO Operating Committee Briefs: June 22, 2023.) CRIS rights are needed to take part in NYISO’s capacity market and can be obtained either through a transfer from a facility with existing rights or from ISO deliverability studies.

Aaron Markham, NYISO vice president of operations, responded, “I believe only half is available to sell capacity.”

Matt Cinadr, a power systems operations specialist with The E Cubed Co., asked whether NYISO has observed any issues with intermittent production and the amount of reserve fuel available.

Markham said, “we’ve definitely seen the levels of intermittent production increasing the volatility on the system, but at this point, it hasn’t been a driver of any reserve shortages.”

“As the amount of intermittents increases, however, I think we’re definitely going to see greater magnitudes of error and need to procure some market products to help manage that going forward,” he added.

DER Manuals

The OC also approved six revised manuals presented by NYISO that will support the implementation of distributed energy resources in New York’s markets.

These DER manuals include revisions to market procedures like ancillary services, control center requirements and emergency operations, and have been reviewed by all other applicable working or stakeholder groups. (See “DER Manual Updates,” NYISO Discovers Market Problem, Opens Confidential Investigation.)

NYISO still anticipates these approved manuals will become effective in parallel with other related DER tariff and market models.

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Energy Transition Costs Give NY Utility Commissioners Pause

The competing goals of reliability, sustainability and affordability converged Thursday as the New York state Public Service Commission wrestled with the mounting costs of the state’s energy transition.

Department of Public Service staff provided the first of what is expected to be a series of annual reports on the agency’s efforts to implement New York’s Climate Leadership and Community Protection Act (CLCPA).

The landmark 2019 law is intended to decarbonize the state over the next quarter century and simultaneously counter decades of environmental injustice.

The costs will be massive, but the details are unknown and likely unknowable at this point.

The figure $270 billion has been thrown around, which is not as big as it sounds when spread over 25 years in a state whose gross domestic product is $2 trillion a year.

But it does not reflect the rampant cost increases of late, nor the delays and cancellations being seen in New York’s renewable energy development pipeline.

Also, the costs will not be spread evenly among the state’s 20 million people.

The federal dollars everyone is counting on to help cover the cost may not last forever, and presumably someday will have to be paid back with interest by federal taxpayers, including those in New York.

Finally, the benefits from all that spending are unknown and will not be reflected entirely in utility bills. Reduced medical expenditures, prevented societal costs, energy efficiency/conservation and increased economic activity are a few of the presumed positives being counted against capital costs as the state calculates a net benefit of more than $100 billion from CLCPA spending.

The PSC and the staff of the DPS will play a key role in much of this spending, as they regulate the infrastructure by which electricity is delivered and the utility rates by which New Yorkers pay for it.

The three primary topics of discussion at Thursday’s PSC meeting all revolved around that theme, and the escalating costs entailed.

Building Electrification

The commissioners unanimously voted to adopt a strategic framework to redirect and streamline the state’s energy efficiency and building electrification efforts (Cases 14-M-0094 and 18-M-0084).

Both cases predate the CLCPA, but they are an indispensable part of any decarbonization and net-zero strategy. Thursday’s order will update the efficiency efforts to better align with the overarching goals of the CLCPA.

Efforts to date have been inadequate in meeting the needs of low- and middle-income New Yorkers, the DPS staff concluded during its review. The new framework will give greater responsibility to the New York State Energy Research and Development Authority for reaching disadvantaged communities.

The order directs NYSERDA and utilities to file within 90 days proposals totaling $1 billion a year from 2026 through 2030, and to look beyond ratepayers for funding.

“Today’s action establishes this framework where we can streamline and scale program delivery,” PSC Chair Rory Christian said, “by moving away from what we previously looked at as individual utility-level goals towards a focus on more statewide outcomes.”

New York state Public Service Commission Chair Rory Christian | © RTO Insider LLC

Commissioner Diane Burman spoke at length about previous efficiency initiatives being a series of good-faith efforts marred by missteps and poor coordination.

Commissioner James Alesi countered with a comparison to the race to put a man on the moon. “There’s going to be failures and there’s going to be frustration,” he said.

Along the way, predicted costs will change and unanticipated costs will arise; new legislation and technology may move the goal line and the path by which it is reached. “But there will be no retreat,” he said. “There cannot be a retreat.”

Commissioner John Howard drilled down on hidden and undisclosed costs. About 20,000 housing units are being weatherized per year across the state, he noted. To meet CLCPA goals, that needs to be 200,000 a year for many years, at a cost of far more than $1 billion a year.

Nonetheless, he called it the first reality-based order he had seen in a long time.

CLCPA Update

DPS Director of Policy Implementation Jessica Waldorf summarized the agency’s inaugural report on the CLCPA implementation (Case 22-M-0149).

The staff-generated review was loaded with technical details such as greenhouse gas emission reductions since 1990 (46%) and a summary of the PSC orders that will help carry out the CLCPA.

There also was a summary of estimated costs authorized as of mid-2023 in support of CLCPA goals: $43.76 billion.

Waldorf said the figures are conservative estimates, and some of the spending was authorized before CLCPA.

The figures will evolve over time, be incurred and paid over an unknown amount of time, and be recovered through a variety of means, not just incremental costs to ratepayers.

But the report gave no estimate of costs to come.

And so began another round of commentary.

New York state Department of Public Service Director of Policy Implementation Jessica Waldorf | © RTO Insider LLC

Commissioner Tracey Edwards said: “I want to see how we can, for the next annual report, do a little bit more of a deep dive on what you expect to happen.”

Berman, too, asked for something more than a retrospective report, as costs are escalating rapidly and are disproportionately being recovered through rates.

“Folks need to understand what it means, and the challenges going forward,” she said. “We have an obligation to look at the total.”

Howard said: “New Yorkers are desperate to know what this is going to cost. The rhetoric around the CLCPA writ large is, don’t worry, it pays for itself. I think we see from our brief snapshot in 2022 … no, it doesn’t pay for itself.”

Commissioner John Maggiore said there are three enormous challenges at play: Keeping energy affordable and reliable while achieving CLCPA goals. “I don’t think achieving any of these things is going to be easy.”

Waldorf said the state has the advantage of a long head start in planning and early results.

“There’s a lot of anxiety out there about how we can actually achieve the goals of the CLCPA but I think we’ve learned a lot through the decades of work.”

The goals will be difficult to achieve, and the shift of investment will need to be significant, she added, but multiple agencies will use every means available to reduce the cost to ratepayers.

One Case of Many

Spiraling consumer costs came to fore yet again in a rate case before the PSC on Thursday, sparking some of the most passionate comments in the lengthy meeting.

The utility with the most customers in the state, Con Edison, in early 2022 sought an increase of 17.6% in delivery charges for electricity and 28.1% for gas, which it calculated would boost customers’ total bills 11.2% and 18.2%, respectively, and give it a combined $1.7 billion in new revenue (Cases 22-E-0064 and 22-G-0065).

It justified the request, in part, by saying it will be spending money on CLCPA-related projects.

This did not go over well with the public and public advocates. The two cases generated more than 7,500 comments.

After investigation and negotiation, the utility, DPS and stakeholders agreed to a pair of rate plans that will give Con Ed a revenue hike of $1.93 billion — 13.5% more than it asked for — but spread that over three years instead of one.

Edwards cast the lone vote against approving the deal.

“I have a tremendous concern about the structure and the process, because we do have a responsibility for balance,” she said, especially with CLCPA looming — “what are all the other investments that have to be made?”

Many families in New York City are still rebounding from the economic crisis wrought by COVID, and have not reached stability, Edwards said.

“My biggest concern, that I just cannot get past, is that the starting point that the utility put in here,” she said. “I just don’t get it. I don’t understand the world they are living in. … We have to change this process.”

Howard tore into the magnitude of the taxes and fees levied on utilities by New York City. (DPS says property taxes account for 21% of a Con Ed electric bill and 15% of a gas bill.)

A majority of the City Council wrote to PSC, urging it to reject the rate proposal, but the council approved without debate an increase in the property tax charged to Con Ed, Howard said.

This will only get worse as Con Ed spends billions on infrastructure needed to electrify the nation’s largest city, he said.

“There is a boomerang of even greater revenue to the city of New York for that expense. As we clean up the environment, we put in this automatic enrichment to the city of New York.”

Christian spoke in more diplomatic terms about the need to pay now for future benefits, and the pain of doing so.

The 7,500 comments are written in different tones and perspectives, he said, but share a common theme: “Recognition that New Yorkers everywhere still face economic challenges coming out of the COVID pandemic. These hardships are only going to be exacerbated further by rising prices.”

Christian added: “I have solace in the fact that these investments are being used to reinforce much of the work we’ve already done in building the system of the future … and creating a better platform from which we can attain our climate goals and maintain reliability of the system.”

Can’t Pay/Won’t Pay

Con Ed’s monthly collections reports to the DPS quantify the trends Edwards and Christian discussed.

New York City suffered significant economic impacts from the COVID pandemic and continues to have a much higher unemployment rate (5.9% in June) than the rest of the state (3.0%) or nation (3.6%).

In June 2023, 473,000 Con Ed customers were more than 60 days in arrears for a total of $1.03 billion. This compares with 327,000 customers who owed $381 million in June 2019, before the pandemic.

Also telling are the numbers from June 2022, when 453,000 customers owed $1.35 billion. A one-time post-pandemic debt forgiveness program the state implemented would soon reduce the arrears by hundreds of millions of dollars — but more of Con Ed’s 3.6 million customers are behind on their bills now than a year ago.

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OSW Industry Group Sees Growth Beyond Turbulence

An offshore wind trade association last week summarized a recent record of remarkable progress in the young U.S. industry but added a caveat: There are severe economic threats to its continued momentum, with project delays and supply chain disruptions likely to continue.

The second-quarter report by the Business Network for Offshore Wind (BNOW) covers a period that contained a major milestone: The first “steel in the water” for the nation’s first two commercial-scale OSW projects — South Fork Wind and Vineyard Wind — following a decade of development work.

The report notes several other measures of progress:

    • An 18% increase in OSW goals backed by legislative or regulatory directive, which reached 42.8 GW nationwide;
    • The formation of a domestic supply chain; the first U.S.-made substation, monopile and export cables installed in U.S. waters; and groundbreaking on a component steel facility in Baltimore;
    • Louisiana undertaking negotiations for wind farms in state waters, which is expected to be a faster development process than in federal waters;
    • Total market investment reaching $21.6 billion, compared with $5 billion in 2021;
    • The fleet of specialty vessels built or retrofitted in U.S. shipyards reaching 36, double the number in 2021;
    • A total of 1,478 contracts awarded, 272% more than in January 2021; 64% went to U.S. companies and 90% went to companies with a U.S. footprint; and
    • 29 ports are under development for manufacturing, marshaling and maintenance.

But then there are the headwinds.

The early wave of OSW projects is concentrated between southern New Jersey and southern Massachusetts, and one after another, developers in that region are saying they no longer can proceed with the projects under terms agreed to years ago because of soaring costs.

The 1,200-MW Commonwealth Wind project has reached an agreement to terminate its power purchase agreements, and the 1,200-MW SouthCoast Wind project is seeking to do the same, both in Massachusetts.

In June, developers of New York OSW projects totaling 4,200 MW told state regulators they may not be able to obtain financing without inflation adjustments.

Projects in New Jersey and Connecticut have sought concessions, as well.

BNOW called this “the duality of the industry” in its report: great strides forward, and a fallback to reassess finances. The trade organization said U.S. and foreign analyses suggest the cost structure has increased at least 20% in the past two years. It expects to start seeing project delays as a result.

In announcing the report, founder and CEO Liz Burdock highlighted the promise of longer-term growth as a new industry takes shape onshore to support the work planned offshore.

“Thanks to supportive federal and state policies, we are seeing unprecedented growth in the U.S. offshore wind supply chain across the nation,” she said Thursday in a news release.

“New contracts are signed daily with a vast majority going to small- and medium-sized American companies creating thousands of new jobs. With $7.7 billion in new U.S. offshore wind investments since the Inflation Reduction Act was signed into law, this is just the beginning. We will see many more factory openings, port revitalizations and vessels under construction in the years to come.”

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Maine One Step Closer to OSW Research Lease

Initial assessment of the offshore wind energy research lease Maine is seeking shows it would cause minimal environmental impact.

The report, by the U.S. Bureau of Ocean Energy Management, is another step toward wind power development in the Gulf of Maine but does not authorize any construction or operation. It entails only surveys, monitoring and placement of meteorological buoys.

Potential negative factors resulting from this work could include air emissions, noise, lighting, seafloor disturbance, entanglements and routine vessel discharges.

Publication of the draft assessment in the Federal Register on Friday started a 30-day comment period, during which two virtual public meetings will be held as BOEM seeks further input before finalizing the assessment.

BOEM rates potential impact at four levels: negligible, minor, moderate and major. Every effect of the research lease was projected as either negligible or minor — including on commercial and recreational fishing, which has been predicted to sustain a major adverse effect in the environmental impact studies prepared for construction and operation of the other wind farms.

Maine is positioning itself to be a pioneer in floating wind and a leader in the industry expected to develop around it. One of its state university campuses has a robust research-and-development program, and it already has floated a small-scale offshore wind turbine in state waters.

A key part of this is the research array Maine is seeking permission to build within a 10,000-acre zone 20 nautical miles offshore — up to 12 turbines with a total nameplate capacity of up to 144 MW.

The offshore wind farm proposals in the pipeline so far are all on the Outer Continental Shelf off the middle and northeast Atlantic Coast, with towers on seabed foundations in relatively shallow waters. The Gulf of Maine, like most of the Pacific Coast, is too deep for fixed-bottom development and will need to rely on floating wind technology that still is being developed and has minimal worldwide operational history.