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August 18, 2024

NYSERDA Signs MOUs to Explore Renewable Projects in Closed Landfills

The New York State Energy Research and Development Authority (NYSERDA) on Monday announced it had signed memorandums of understanding with Tompkins and Orange counties to study the feasibility of developing renewable energy projects in underutilized landfills.

The installation of large-scale renewable projects has seen community pushback, but the prospect of siting them in an area devoid of people is an opportunity for New York to make progress on its energy and climate goals.

“The town of Dryden is looking forward to participating in the review of this project,” town Supervisor Jason Leifer said in a statement. “Using brownfields for this purpose is preferable to using farmland.”

Both the 112-acre Caswell Road landfill in Tompkins County and the 420-acre Orange County landfill have been closed for several decades. NYSERDA said their transformation into potential renewable energy sites represents progress under the Accelerated Renewable Energy Growth and Community Benefit Act and the agency’s Build-Ready Program.

EPA has been encouraging the development of landfill solar and/or storage projects across the U.S. via its RE-Powering Initiative, which it estimates has grown by 80% the past five years. A 2021 report from RMI found that the more than 10,000 closed and inactive landfills around the country could host an estimated 63 GW of solar capacity, but only 500 MW had been installed.

Houston recently proposed a plan to change its Sunnyside landfill into a 70-MW solar panel farm, while the Hickory Ridge landfill in Georgia has been covered with a geomembrane anchoring system that has transformed the site into one the state’s largest solar generators. New Jersey recently opened a 25.6-MW solar farm in the Combe Fill North landfill, which hosts 56,000 solar panels on a brownfield site that had been closed since 1978.

NYSERDA CEO Doreen Harris said in a statement that “these agreements with Tompkins County and Orange County will help us to better understand the viability of these landfills for potentially hosting a large-scale solar project.”

Shawna Black, chairwoman of the Tompkins County Legislature, said that “the potential to generate solar energy from the Caswell Road site is huge,” while Orange County Executive Stefan M. Neuhaus said the “project will help further the county’s energy-efficiency initiatives.”

Anne Reynolds, executive director of Alliance for Clean Energy New York, said “repurposing industrialized lands for the production of pollution-free power is good policy, and we applaud this collaboration with Tompkins and Orange counties.”

Jean Hamerman, executive director of the Center for Land Recycling, said “closed landfills represent an ideal opportunity to reduce our fossil fuel dependence through solar development.”

In an email to NetZero Insider, a NYSERDA spokesperson said that the agency is “evaluating both sites for solar PV coupled with battery energy storage systems” and that, through the Build-Ready Program, it will “pursue site control and preconstruction development activities prior to competitively auctioning the developed sites.”

“Future announcements will be made as the Build-Ready Program continues to de-risk the projects and move them towards a competitive auction to private-sector developers to construct and operate,” the spokesperson said.

Orsted, Eversource Propose Revolution Wind 2

Ørsted and Eversource are proposing an 884-MW wind farm off the coast of Rhode Island.

Monday was the deadline to respond to the state’s 2022 request for proposals, which seeks to add 600 to 1,000 MW of offshore wind to the state’s grid.

PPL (NYSE:PPL) subsidiary Rhode Island Energy, which is running the offshore wind solicitation and will buy the power that it generates, told NetZero Insider Monday it would not immediately be releasing details of this solicitation.

But Ørsted and Eversource announced their proposal shortly after the noon deadline: Revolution Wind 2, an 884-MW project that would provide a $2 billion boost to Rhode Island’s green and blue economies, plus direct and indirect benefits in port infrastructure, job creation, environmental justice and workforce development in historically marginalized communities.

The two companies are partners on the 704-MW Revolution Wind 1, which would send electricity to Connecticut and Rhode Island. They also are collaborating on Sunrise Wind 1 and South Fork Wind and have proposed Sunrise Wind 2, all of which would feed New York’s electric grid.

Ørsted is the largest offshore wind developer in the world. Its portfolio includes Block Island Wind Farm off the Rhode Island coast, a five-turbine, 30-MW project that was the first commercial offshore wind farm in the United States. The company also is pursuing projects in New Jersey and Maryland.

Eversource, the largest energy provider in New England, is looking to sell its offshore wind interests but has said the process is taking longer than first expected.

Ørsted and Eversource said in a news release Monday that if their proposal was accepted, it would provide $35 million to a planned regional offshore wind hub at Quonset Point; result in local construction of two new crew transfer vessels in addition to the five already being built; and result in creation of a Rhode Island engineering center that would employ 75 engineers and serve as a U.S. hub for Ørsted.

Rhode Island’s second offshore wind solicitation opened Oct. 14, a result of clean energy legislation signed by Gov. Dan McKee in July 2022. McKee indicated then that the additional offshore wind power — combined with Block Island Wind Farm and the 400 MW of Revolution Wind 1 — could meet half of the state’s projected 2030 electricity needs.

It is an important part of the state’s strategy to use 100% renewable energy by 2033 and achieve net zero status by 2050.

Rhode Island Energy’s current timeline for the 2022 solicitation calls for review of bids with the state Office of Energy Resources on March 20; conditional selection of bidder(s) for negotiation of contracts on June 21; and submission of contracts for Public Utilities Commission approval on Nov. 13.

NY OSW Developers Propose Collaboration with GE

Details of New York’s third round of offshore wind proposals suggest a potentially significant role for General Electric (NYSE:GE) in the supply chain that the state hopes to host for the new industry.

New York aims to have at least 9 MW of offshore wind in service by 2035, and there is talk of kicking the goal significantly higher.

Along with clean energy, officials want the derive an economic boost and social change from the projects; this latest offshore wind solicitation stipulated that proposals detail the efforts developers would take to encourage formation of ecosystems to build wind power components and grow a workforce.

After the solicitation closed, GE said that if enough orders arose, it would build two factories — one for turbine nacelles, and one for blades — in an area of upstate New York that is shaping up as a potential center of manufacturing and fabrication for offshore projects.

Competitor Siemens Gamesa said it would build a turbine nacelle factory nearby, again conditioned on it receiving orders for its products for use in New York waters.

Vestas is also in the mix, potentially building a blade factory in the same area as other proposed facilities. All would sit on the Hudson River, more than 100 miles from the ocean but easily accessible with barges or even deep-draft vessels.

Extensive documentation posted recently by the New York State Energy Research and Development Authority shows that all six developers submitting proposals in the 2022 OSW solicitation would rely on GE as potential suppliers. The thousands of pages of information are redacted to varying degrees.

Attentive Energy One, a joint venture of TotalEnergies (NYSE:TTE) and Rise Light & Power, would be a 1,404-MW wind farm with 1,310 MW of net delivery to the point of interconnection. The proposal emphasizes two priorities for New York — environmental justice and just transition — by highlighting its plan to land power cables at an aging fossil-fired power plant in New York City. The proposal states that current workers at the plant would keep their jobs, fewer nearby residents would develop asthma, and there would be little opposition to landing the power lines there. The total economic benefit to the state is pegged at $25.6 billion over 25 years.

Sunrise Wind 2 would be a joint venture of Orsted and Eversource Energy (NYSE:ES), which opted to keep such details as nameplate capacity secret in the public version of their 1,381-page proposal. But the unredacted passages emphasize their experience alone — Orsted as the largest OSW developer in the world, Eversource as the largest energy provider in New England — and together, including ongoing construction of South Fork Wind and development of Sunrise Wind 1, both off the New York coast. It is not clear if they mention that Eversource is actively attempting to sell its stake in the partnership, or that Orsted expects a significant cost impairment on Sunrise 1, because of escalating costs.

Beacon Wind 2 would be developed by Equinor (NYSE:EQNR) and bp (NYSE:BP), which already are developing Empire Wind and Beacon Wind 1. Few details are offered publicly about Beacon Wind 2, except that they would partner with GE on nacelle and blade manufacture, and with another firm on manufacture of high-voltage underwater cable, also in New York. In a January news release, the partners said Beacon 2 would generate 1.36 GW of electricity and more than $11 billion in economic activity.

Community Offshore Wind, proposed by RWE and National Grid Ventures, could be built in 1.3- or 2.6-GW configurations with a variety of price points. They propose collaboration with GE in the Albany area and creation of an offshore steel hub at a site along the Hudson between the Atlantic Ocean and Albany. The two tout their $1 billion-plus investment to date in clean energy in New York, including RWE’s onshore wind farms upstate. They note RWE’s status as the No. 2 offshore wind developer in the world, and the century-plus history in New York of some of National Grid’s operating companies.

Leading Light Wind is proposed by Invenergy as lead developer and energyRe as co-developer. In what is perhaps the least redacted of the proposals, they offer 1.32- and 2.1-GW proposals, with an optional energy storage component. They highlight their status as the only American-led project in the New York Bight; as developer of Clean Path NY, the HVDC line that is an important part of the state’s energy transition strategy; and Invenergy’s track record of over 890 MW of solar, wind and storage in the state. They say the project would provide up to $13.3 billion in economic benefits for the state and include a stakeholder outreach process guided by “humility, creativity and connectivity.”

Excelsior Wind, Liberty Wind North and Liberty Wind South are proposed by Vineyard Offshore. Its proposal is perhaps the most redacted of the six developers’ material, with minimal information made public. Vineyard would partner with GE on blades and nacelles for the projects and with some other entity on cable manufacturing. A January news release by Vineyard said the plan would produce 2.6 GW of electricity and more than $15 billion in economic benefits. Vineyard is a partner in the Vineyard Wind 1 project being built off Massachusetts.

PJM OC Briefs: March 9, 2023

VALLEY FORGE, Pa. — PJM’s Operating Committee voted to approve a proposal to allow for cost recovery for facilities determined critical for interconnection reliability operating limits (IROLs) under NERC Critical Infrastructure Protection (CIP) standards.

The PJM-endorsed package received 89% support over the status quo, while an opposing proposal from the Independent Market Monitor received 11%.

PJM’s Darrell Frogg likened the structure to the payments received for providing black start service in that the costs to comply with the requirements can be submitted to both the RTO and Monitor for review and monthly payments would be made through revenue socialized across market participants.

PJM and several stakeholders supporting the proposal argued that having an asset designated as critical infrastructure is beyond the control of an owner, comes with significant financial burden and is unpredictable for market participants because the analysis PJM conducts to identify critical facilities doesn’t look far enough ahead for a generator to include any expenses in future Base Residual Auction (BRA) offers. (See “No Consensus on IROL-CIP Cost Recovery,” PJM OC Briefs: Feb. 9, 2023.)

PJM’s proposal calls for cost recovery to be conducted over 12 months, which supporters pushed for on the basis that CIP status can change annually, creating the prospect that a facility could be designated critical and then have that status reversed shortly after the required upgrades have been completed.

Monitor Joseph Bowring contended that PJM runs markets and is not a cost-of-service regulator, saying there is no justification for having a separate cost-recovery mechanism outside the markets. He also argued that there are substantial differences between IROL-CIP and black start, and that there already are ways for generators to represent the costs of IROL-CIP upgrades in their market offers, which he said is the appropriate place to include costs.

The proposal Bowring presented to the OC would have memorialized that “there is no PJM cost of service recovery mechanism for IROL CIP costs under the PJM governing agreements” and that market participants can instead recover their costs through the existing markets.

Updated Information on Winter Storm Generator Outages

PJM’s Dan Bennett presented more detailed analysis of generator outages during the Dec. 23 winter storm, which shut down more than 23% of capacity in the PJM fleet. (See PJM Gas Generator Failures Eyed in Elliott Storm Review.)

The new data, which was collected from generators reporting to NERC’s Generating Availability Data System (GADS), shows the impact of the total of 2.4 TWh of forced outages over Dec. 23-25. Gas-fired units made up 63% of the unavailable capacity, followed by coal at 28%. All other fuel types represented under 5% of the forced outages during the storm. 

The loss of gas supply was the largest reason for gas outages, constituting 31% — or 473,208 MWh — of unavailable capacity, followed by freezing and plant equipment issues. More than half the coal outages were attributed to boiler issues. Across resource types, fuel availability accounted for nearly 500,000 MWh of outages, nearly matched by issues with plant equipment. 

Bennett said also that the bulk of unavailable generation did not have a commitment in the day-ahead market, representing 64% of the missing capacity at 7 a.m. on Dec. 24, the peak of the outages. Day-ahead commitment played an even greater role for gas generation, with those lacking a commitment making up 72% of the forced outages; for outages attributed to gas fuel supply issues that figure rose to 89%.

Paul Sotkiewicz, of E-Cubed Policy Associates, said he believes many of the forced outages attributed to gas supply are being misrepresented and that generation may not have been called upon at all and was instead asked to incorrectly take forced outages in some cases. He also questioned how many of the outages could be related to PJM’s forecast, which underestimated temperatures and the amount of generation that would be needed during the storm.

“I’m understanding that there were many resources that were available but were simply not called upon by PJM, and that gets into the question of why that was the case,” he said.

PJM’s Chris Pilong said the data being presented Thursday was based on further analysis of GADS reporting, which would not capture the issues raised by Sotkiewicz, which could be addressed in future presentations to the Market Implementation Committee or in the final report to be released later this year. Sotkiewicz said he believes the OC is the proper forum for that information, which involves how gas nominations are understood operationally.

During an earlier presentation on daily peak forecast error, PJM’s Hong Chen told the OC that demand response load reductions were smaller than the initial estimates, meaning the load forecast error was also lower than originally reported.

Responding to questions about how that is reflected in the data Bennett presented, Pilong clarified that Chen’s presentation was not reflecting that demand response underperformed, but instead that it’s the “measure of expectation.” When calculating the amount of load reduction received by DR, it was not taken into account that some of the load curtailed would already be switched off prior to the DR dispatch. While the amount of load reduced is smaller than expected, the amount of generation offline was the same.

PJM Drafting Comments on Virginia Environmental Rule Change

PJM is planning to submit comments to the Virginia Department of Environmental Quality on a rule change to allow data centers to receive variances expanding the usage of on-site generators when the RTO has declared a maximum generation emergency. 

In the announcement of the comment period, which is open through early April, the DEQ said an area in Fairfax, Loudoun and Prince William counties was identified to be at risk of having inadequate transmission capability going into the summer months. The DEQ subsequently revised the proposal to apply only to Loudoun County.

Presenting to the OC, PJM’s Gary Helm said the comments will likely focus on the conditions that would lead PJM to issue a maximum generation alert and how that would interface with the rule change. He noted that PJM recently released a white paper on the balance between resource development, retirements and load growth, which included the accelerating demand from the Data Center Alley centered on Loudoun County. (See “PJM White Paper Expounds Reliability Concerns,” PJM Board Initiates Fast-track Process to Address Reliability.)

Adrien Ford, of the Old Dominion Electric Cooperative (ODEC), recommended that PJM increase its contact with data center developers and operators to get a better understanding of the emergency generators being installed there and the impact that backups of that scale could have on the grid if they go online.  

“They’re so big, and some of these are measured in gigawatts not megawatts,” Ford said of the data centers, questioning if the emergency generators would cover a portion or the whole of the data centers’ load.

PJM’s Donnie Bielak said that although PJM does not have dispatch control over the generators, it’s aware of what is being installed and is ready for them in terms of emergency conditions.

Transmission Outage Coordination Proposals Discussed

Stakeholders discussed two proposals being drafted by the Monitor and a joint package from PJM, Public Service Enterprise Group (NYSE:PEG) and DC Energy on coordination between utilities and PJM for extended transmission outages. (See “Outage Coordination Issue Charge Endorsed,” PJM Operating Committee Briefs: May 12, 2022.)

The Monitor’s package would aim to ensure that events like the surge in congestion pricing caused by line work in Virginia’s Northern Neck peninsula are prevented or limited when possible by correctly identifying likely congestion impacts in advance of approving the outages and requesting alternative approaches by relevant transmission owners. 

The package would also seek to ensure that outage submission deadlines are enforced prior to FTR auctions and the closing of the day-ahead market. The package would more generally help ensure the provision of more accurate and timely information to all customers about transmission outages, increasing transparency around when they will occur and allowing customers to better plan for them. Bowring said PJM’s current rules need to be strengthened and enforced and must include more clearly defined consequences for utilities that do not provide that information.

The revisions the IMM is proposing in its package include:

  • treating a request to reschedule an outage as a new request or as a late submission if they try to reschedule too far out;
  • clarifying the definition of the congestion analysis required for outage requests;
  • rewriting rules to reduce or eliminate approval of late outage requests after FTR auction bidding opens;
  • preventing transmission owners to divide long duration outages into smaller segments to avoid the requirements for longer outages.

In response to the IMM presentation, Exelon’s Sharon Midgley said the outages must be looked at from a reliability lens, not just market impact, adding that they’re necessary for maintenance and implementing capital projects. She said the existing rules are already clear, and levy consequences for being late and have protections to ensure that outages that would cause congestion aren’t approved if they are submitted late. Midgley also noted that much of the IMM proposal is outside the scope of the OC-endorsed stakeholder deliberation as it contains many aspects that conflict with the PJM Consolidated Transmission Owners Agreement (CTOA).

Bowring acknowledged that TO must take outages to support a reliable transmission system but that there are no consequences for not following the existing rules that require clear public notice about those outages, and that the rules are frequently not followed as documented in the Market Monitor’s presentation to the OC.

The joint proposal would expand the transmission outage information shared by PJM, expand the switching solutions information PJM provides and change the Regional Transmission Expansion Plan (RTEP) outage coordination process to have PJM staff review approved RTEP projects to identify those that may require extended outages and to then coordinate with TOs to assess the need for those outages and their impacts.

Illinois Commerce Commission Chair Announces Resignation

[EDITOR’S NOTE: A previous version of this story incorrectly implied that Zalewski has abstained from every case involving ComEd before the commission.]

Illinois Commerce Commission Chair Carrie Zalewski announced her resignation days before the beginning of the first of two Commonwealth Edison bribery trials in which the Justice Department will try to prove the utility engaged in a years-long scheme to bribe elected Illinois and Chicago politicians for legislation and policies favorable to the company.

Zalewski, a litigation attorney and former assistant chief counsel for the Illinois Department of Transportation and nine-year member of the Illinois Pollution Control Board, was appointed ICC chair in April 2019.

She is the spouse of former State Rep. Michael Zalewski (D), a member of the Democratic House caucus controlled by Speaker Michael Madigan (D), and the daughter-in-law of former Chicago alderman Michael Zalewski (D), who prosecutors said benefited from ComEd’s bribery scheme.

pramaggiore-anne-2018-12-05-rto-insider-fi-1.jpgAnne Pramaggiore, former ComEd CEO | © RTO Insider LLC

Prosecutors say that then-ComEd CEO Anne Pramaggiore agreed in 2018 to pay the former alderman about $5,000 a month at Madigan’s request.

Zalewski has not been charged in the bribery probe and told the Chicago Sun-Times she doesn’t expect to be called to testify in the upcoming trial. She declined to comment when asked if she has been questioned or subpoenaed by federal authorities.

Zalewski abstained from voting on one ComEd case since federal prosecutors made the probe public two years ago on the advice of the commission’s general counsel and ethics officer because of the possibility that a relative might have had to testify.

In a LinkedIn post Thursday, Zalewski announced she would resign effective June 16, seven months before her term expires on Jan. 15, 2024. Her five-page resignation letter expressed pride in the ICC’s role in implementing the Climate and Equitable Jobs Act and in providing bill relief to consumers during the COVID 19 pandemic. She did not give a reason for her resignation.

Dozens of colleagues responded to her posting with praise. “Congratulations on an incredibly successful and productive tenure at the ICC!” wrote former Michigan commissioner Sally Talberg.

Gov. JB Pritzker announced Zalewski’s resignation in a joint release Friday.

“Chairman Zalewski served the state of Illinois diligently during a period of challenging unprecedented circumstances and clean energy transition, and her stalwart leadership was essential to the successes of that period,” Pritzker said. “I’m so grateful for her years of service and the long-lasting impact her work will have on building a more equitable and sustainable Illinois for generations to come.”

Pritzker said he will nominate former ICC Chair Doug Scott to replace Zalewski. Scott served as chair from 2011 to 2015 and is the former director of the Illinois Environmental Protection Agency. He is currently vice president of strategic initiatives at the Great Plains Institute.

The governor also announced the appointments of Conrad Reddick and Stacey Paradis to the five-member commission.

Paradis is currently the executive director of the Midwest Energy Efficiency Alliance. Reddick, an attorney, previously represented the Illinois Industrial Energy Consumers and served as special assistant corporation counsel to the city of Chicago on utility oversight issues.

Mike-Madigan-Ill-Legislature-Content.jpgMichael Madigan, former speaker of the Illinois House | Illinois Legislature

In the first bribery trial scheduled to begin March 14, Pramaggiore and three political lobbyists face charges that they schemed to corrupt Madigan, who was the longest-serving state house speaker in the nation.

Prosecutors have alleged the company created a scheme to pay Madigan’s associates over years with contracts, jobs and company internships through “an old time patronage scheme.” (See How ComEd Got its Way with Ill. Legislature.)

The defendants have said their activities were typical of a utility and that the government is seeking to criminalize legal lobbying.

Madigan’s trial is set for April 2024.

ComEd signed a deferred prosecution agreement with the U.S. Attorney’s Chicago office in July 2020, admitting to its efforts to corrupt elected officials, agreeing to pay a $200 million fine and to cooperate with the on-going investigation. (See ComEd to Pay $200 Million in Bribery Scheme.)

PJM PC/TEAC Briefs: March 7, 2023

PC Discusses Attachment M-3, Transmission Upgrade Timeline

VALLEY FORGE, Pa. — The PJM Planning Committee last week discussed the remaining open action items in tariff Attachment M-3, which describes the process by which transmission owners plan supplemental projects in coordination with the RTO’s development of the Regional Transmission Expansion Plan (RTEP).

Much of the discussion centered on the amount of time between TOs’ submission of needs for projects and their proposed solutions, with there currently being no specified timeline to follow.

Alex Stern of Public Service Enterprise Group said there was significant discussion between PJM and TOs following feedback from stakeholders that the amount of time between needs being brought before the Transmission Expansion Advisory Committee and proposed solutions was often too long, sometimes more than a year. He said TOs felt that was a valid concern and have asked their planning staff to bring solutions back sooner.

“Thus far it’s an informal monitoring process, but the TOs so far are not seeing the same degree of problem that inspired the concern,” Stern said. “And by that I mean we definitely heard about the need being brought and then the solution not being brought for a significant amount of time after that, but the TOs heard the critique, believe it has been addressed and are not seeing that issue continuing to be a problem.” He added that if significant gaps start to reappear, those concerns should be voiced.

PJM’s Sami Abdulsalam said the RTO is considering that action item in the ongoing review of Attachment M-3 to be closed.

Update on RTEP Window 3

Abdulsalam provided the TEAC with an update on the ongoing 2022 RTEP Window 3, which opened on Jan. 31 and is scheduled to close on April 25. The window was added to the RTEP to address reliability needs caused by rising load expected from data centers in the Dominion and APS transmission zones. (See “Load Forecast for Northern Virginia Data Centers Continues to Climb,” PJM PC/TEAC Briefs: Jan. 10, 2023.)

Solutions should be expandable and scalable to allow them to address future expansion beyond the 2027/28 delivery year should the data center load growth continue, as is expected. The constraints in the 2027/28 baseline include the 230-kV substations serving local load into points of delivery and regional constraints primarily being seen on the 500-kV system importing energy into the region. They should also address any new violations created by the proposal itself to be considered.

FERC Seeks More Funds, Employees in Latest Budget Request

FERC on Monday released its fiscal year 2024 budget request, with the regulator seeking a total budget of $520 million for the year.

The commission recovers the full costs of its operations through annual charges and filing fees assessed on the industries it regulates and deposits that with the Treasury, offsetting its congressional appropriations entirely.

The funding request is about 2.3% above fiscal year 2023 and includes the hiring of 58 additional full-time equivalent employees, bringing the total number of staff at FERC to 1,566.

“The additional resources will allow the commission’s program offices to undertake forward-looking strategic studies and expand external engagement efforts with a wide range of stakeholders,” FERC said. “In addition, targeted FTE investments will enhance the commission’s advisory services, strengthen organizational capabilities, streamline processes and minimize inefficiencies to address the commission’s evolving mission requirements. The FTE increase will continue to directly staff the new Office of Public Participation established in FY 2021.”

The first priority that the document lays out for FERC in the next fiscal year is to modernize electricity market design.

“Current market designs may not allow for the operational flexibility needed to address changing system needs that are being driven by an evolving resource mix and changing load profiles,” FERC said. “The commission will work with stakeholders to explore the gaps in current electricity market designs and identify potential reforms to modernize them.”

FERC started that work in FY 2022, requiring additional information in parties’ electronic quarterly reports. It has also worked to improve credit rules in the ISO/RTO markets.

This year and next, FERC will continue to evaluate the impact of the new database on the market-based rate program and evaluate credit rules, it said.

Another priority is to facilitate the development of the electricity infrastructure needed for the changing resource mix, FERC said. A large amount of new transmission is needed to address the challenges of and facilitate the interconnection of large quantities of new renewable resources in the markets while preserving reliability. The commission has issued some proposals on transmission planning and interconnection queues, and it will continue to evaluate those going forward, it said.

On its enforcement efforts, FERC said it was starting to make use of new technology and plans to transfer key data assets into the cloud by the end of this fiscal year. Moving surveillance screening and analysis to the cloud will make it work better and improve staff’s ability to monitor electric and natural gas markets, it said.

Another one of FERC’s goals for the fiscal year is to continue safeguarding infrastructure from threats to reliability and security, such as extreme weather, climate change and cyberattacks.

“The commission will address this priority through an integrated set of targeted actions designed to mitigate or avoid the adverse effects of widespread and extended power outages caused by these threats,” FERC said.

WPP CEO Looks to ‘Earliest Possible’ Binding Season for WRAP

Western Power Pool CEO Sarah Edmonds would like to see the Western Resource Adequacy Program (WRAP) become “binding” on its participants as soon as possible, but making that transition could still be years away, she said last week.

After winning FERC approval for the WRAP tariff last month, WPP now has the option to initiate the binding phase of the program during any season between 2025 and 2028. At that point, participants will subject to “very, very significant” penalties for not meeting their resource adequacy obligations outlined under the program, Edmonds said in a briefing to WECC’s Board of Directors on Wednesday.

Edmonds emphasized that the WRAP is not the product of any state or federal requirements but was developed by electric industry participants as a voluntary program to address concerns about imminent RA shortfalls in the West.

“Once [load-serving entities] are in the program, they are obligated at least for a period of two years to fully comply with all the [RA] metrics, so to get these companies comfortable with jumping into this compliance framework, where there are significant consequences, we have to offer some flexibility about when the binding season will occur,” Edmonds said.

The current “nonbinding” phase continues to offer important lessons for participants, she pointed out.

“To be candid, some load-serving entities are in better shape to go binding than others. Others need a little more time to adjust their procurement strategies and their positions relative to what they see coming at them,” she said.

Edmonds said the WPP is in a “very active” discussion with the WRAP’s current 19 participants about when to enter the binding phase.

“I will certainly be pushing for the earliest possible binding season, but we also have that built-in flexibility, and that was the bargain that we struck to get this program off the ground,” she said.

‘Insurance Policy’

Edmonds outlined some of the challenges — and risks — participants face in entering the binding phase. She said the WRAP is “a little novel” compared with other RA programs in that it includes a strict deliverability requirement, which stipulates that a resource must have 75% firm or conditional firm transmission from source to sink to be considered compliant with the program’s counting rules.

Seven months ahead of a season, a participant must provide WPP a “workbook” of “forward showings” of their RA, which the program operator evaluates to ensure the participant is meeting its specific allocation of the WRAP planning reserve margin.

“When we say you’re a little bit short, and you have few months to cure, if you don’t cure, you are subject to pretty significant penalties,” Edmonds said. “They are of such significance that they’re really trying to send an economic signal that you should not lean on this program. You cannot rely on this program to serve your load; you need to solve your own problem.”

Once a season becomes the current operations period, the program operator will monitor conditions and notify participants of any expected RA deficits relative to their workbooks seven days in advance of an operations day.

“If they want to go out and fix that problem without relying on the program, we encourage it. The program is not meant to be the first go-to place for serving load; it is meant to be an insurance policy … a backstop,” Edmonds said.

From an operational standpoint, the WRAP “is really delivering surplus to deficit entities in those hours of highest need,” Edmonds said. “It relies entirely on using traditional bilateral trading mechanisms and transmission which is sold under open-access transmission tariffs. We’re not a market; we’re not creating anything there. We’re relying on what’s out there, but we are matching up the surplus and the deficits and creating the overall structure.”

Edmonds likened the WRAP to a contingency reserve program “in the sense that we are creating a pool with the right to call on the pool.”

“Those entities receive that insurance policy. They get help through that difficult day to serve their load,” subject to paying a settlement price for drawing on the pool, she said.

And while the WRAP has the potential to reduce its participants’ planning reserve margins over time through more coordinated resource sharing and a greater diversity of resources, getting there is part of the broader learning process of the nonbinding phase, Edmonds said.

“Is everyone in a position to yield that benefit right away? Probably not. I mentioned to you that there are some entities that are going to have to adjust into that position over a period of time. But overall, and in the long term, the goal of the forward showing is to get to that lower potential position,” Edmonds said.

Decarbonizing the Grid Faces Hurdles Despite Recent Laws

WASHINGTON — The Inflation Reduction Act and Infrastructure Investment and Jobs Act passed last year have given the renewable energy industry policy certainty with hundreds of billions of dollars in funding, but the industry faces some challenges in maximizing its opportunity.

“For the long term, we have the challenge ahead of us on transmission, building up the workforce that we need, on supply chain — all those things need to come together,” Enel North America’s head of public policy, Jack Thirolf, said at ACORE’s Policy Forum on Thursday. “And we need to not wait.”

One of the short-term issues facing the industry is waiting for the Treasury Department to implement many of the IRA’s tax provisions, but that has not stopped development, according to Bank of America Managing Director Ray Wood.

“We haven’t stopped to wait for guidance,” said Wood. “We continue to work on transactions.  We’re seeing an incredible flow of opportunity to deploy capital. And we’re very excited about the prospects of the IRA bringing down the cost of capital for our clients and for the industry, thereby allowing for more deployment to bring in domestic manufacturing.”

General Electric (NYSE:GE) thinks about the transition to a clean grid globally, which means it has to start making decisions about which technologies to ramp up manufacturing now so they can be deployed as needed, said GE Renewable Energy Senior Executive Director Chrissy Borskey.

“There’s got to be some things that, as an industry, we can start thinking about it, and we can start saying, ‘This is what we need today,’ or ‘this is what we need in the next three months,’” said Borskey. “And we’re going to have to prioritize.”

Meta (NASDAQ:META) Head of Renewable Energy Urvi Parekh said the internet giant has been on average making about 2,000 MW worth of renewable power purchase agreements every year recently, but this year could threaten that streak. The industry needs guidance on exactly how the IRA’s incentives will work, and that uncertainty is leading to more expensive PPAs.

“I’ll know it’s working when we start to see clarity in the prices that we’re seeing,” Parekh said.

Supply Chain Issues Must be Overcome

Another challenge that has roiled the industry along with the rest of the economy recently is the supply chain. The new laws require more domestic manufacturing of goods such as solar panels, which are dominated by China now.

The Chinese dominate the manufacturing of polysilicon and wafers, which are key components to manufacturing solar, said Becca Jones-Albertus, director of the Department of Energy’s Solar Energy Technologies Office.

“A supply chain that has a heavy domestic component brings all kinds of other benefits,” said Jones-Albertus. “Economically, it brings resilience to shipping issues, in which we saw seeing a huge cost increase over the last couple of years.”

Onshoring the supply chain also means more jobs and all the economic benefits that come with increased employment, she added.

Ørsted Americas Head of Program Execution Troy Patton said his firm, which is building seven offshore wind projects off the East Coast, buys from the entire market, so as long as supply can meet demand, the Danish firm does not run into supply chain issues.

“As long as there’s economically feasible supply, we’re happy with the security of supply,” Patton said.

However, while the onshore wind industry in the U.S. has developed its own domestic manufacturing and supply chains, the more nascent offshore industry has not, to the point where Ørsted is having to import all the major components for its first projects, he added.

Securing the solar supply chain is going to involve a lot of tough work, said Nextracker Vice President of Government Affairs Kathy Weiss. Her firm found some success in getting “trackers” that help panels follow the sun built domestically, but that involved reaching out to steel manufacturers and assuring them that the demand for the devices would be there for years to come.

China built up its dominance over 20 years, but the U.S. Commerce Department has issued tariffs on that country, in what has become a bipartisan and popular policy.

“For 20 years, China has been publishing a five-year plan that says, ‘We’re going to dominate,’” Weiss said. “And so now we just figured that out, and we’re trying to react to it; I hope the reaction is one that is smooth and not jarring for the industry.”

An executive order from President Biden gave the industry a stay on the tariffs, which will give it a couple years to rearrange supply chains and use IRA funding to build up domestic manufacturing of solar, she added.

“All our companies across the industries have jumped on that and are working 24/7 to try and stand up fast; to get partners that we’ve worked with offshore to bring them the equipment onshore; to get the equipment set up; get the workers trained; to get the steel prepared,” Weiss said. “So that activity is happening at every renewable energy company across the United States.”

Grid Needs to Triple in Size

Fully decarbonizing the electric sector is going to take massive amounts of new resources, with DOE’s latest modeling showing another terawatt each of wind and solar, about 500 GW of other renewable sources and 300 GW of battery storage. Linking it altogether will also require significant amounts of new transmission, said acting Assistant Secretary for Energy Efficiency and Renewable Energy Alejandro Moreno.

“The modeling that we’ve done looks at sort of the base scenarios that we have increasing transmission by three times above current levels,” he added.

Federal support is needed to get that transmission built out, but it is not enough on its own, said Brian George, Google’s (NASDAQ:GOOGL) U.S. federal lead on global energy market development.

“The large buyers who need access to transmission really have an obligation to be engaged in our communities, in our local environments, to talk about the benefits that these projects have,” George said.

Cost allocation is another key area that needs to be tackled, and that will largely involve states coming to an agreement on where the most beneficial pathways for power are and agreeing to share the costs of new transmission, he added.

The industry has been run the same basic way for 100 years, with policies on top of an original framework that needs to be reformed from the ground up, said Breakthrough Energy’s manager of U.S. policy and advocacy, James Hewett.

“So how do we start to kind of pull those bricks down and build the grid that we know that we need?” said Hewett. “And that’s obviously going to be a really difficult challenge.”

The grid is the “most important machine in our society,” and too often transmission expansion is narrowly focused on the needs that one project will address, said Dominion Energy Senior Vice President of Corporate Affairs William Murray. Such a narrow focus means most people will never be interested in that work.

“What we’re doing instead is strengthening the most important machine in our society for decades and decades,” Murray said. “But we’re also enabling the most significant economic transformation since the internet. And that’s kind of cool.”

FERC is not focused on bringing down barriers to new transmission because it is doing the job assigned to it instead: making sure rates are just and reasonable, said its special counsel, Kim Smaczniak.

The commission has three proposals aimed at improving its transmission regulations, including a Notice of Proposed Rulemaking on transmission planning that would require more long-term planning of 20 years based on various scenarios of a future grid. It also has a NOPR on changes to interconnection queues to speed up the process of connecting new generators, after many of the current rules have led to ever ballooning delays for projects.

The third major rule Smaczniak and colleagues at FERC are working on is an update to the commission’s backstop transmission siting authority from the Energy Policy Act of 2005, which was recently clarified in the IIJA to say that the federal agency can overrule a state that rejects a line.

GCPA Speakers Embrace MISO Sloped Demand Curve

NEW ORLEANS — The likelihood of a sloped demand curve in MISO’s capacity market earned seals of approval from panelists at Gulf Coast Power Association’s 9th Annual MISO/SPP Regional Conference March 8-9.

MISO Independent Market Monitor David Patton said he recommended the grid operator adopt a sloped demand curve for about 20 years, to remedy its “broken” capacity construct.

Patton said he assumes that stakeholders opposed to a sloped curve are acting in their self-interest. He said members sooner or later must accept that they may have to purchase capacity “that keeps the lights on” in a market structured to reflect capacity’s marginal reliability.

MISO is intent on designing and implementing a downward-sloping demand curve by its 2024/25 capacity auctions. It will replace a demand curve that abruptly cuts off excess capacity’s value when reserve margin requirements are satisfied. (See MISO Charts Course on Capacity Auction’s Sloped Demand Curve.)

The grid operator is proposing four sloped demand curves for each of its seasonal auctions based on separate seasonal reliability targets. Its analyses have shown an incremental value for capacity procured beyond the summer reliability target.

Todd Ramey 2023-03-08 (RTO Insider LLC) FI.jpgMISO Senior VP Todd Ramey | © RTO Insider LLC

“Historically, as an industry, resource adequacy was binary. Either you had it or you didn’t,” said Todd Ramey, MISO’s senior vice president of markets and digital strategy.

Ramey said that the paradigm led to the RTO’s longstanding vertical design.

However, he said a 1.2-GW shortfall in last year’s capacity auction chipped away at MISO’s one-day-in-10-year reliability standard to a “one-in-eight, one-in-five year.” (See MISO’s 2022/23 Capacity Auction Lays Bare Shortfalls in Midwest.)

“When we started, we had a pretty healthy reserve margin for the footprint,” Ramey said. “Here we are 10 years later, and we’ve been wildly successful at bumping down our reserve margin.”

He said the static demand curve has produced capacity pricing that is “inefficiently low” to spur new generation development.

Patton said that had MISO used a sloped curve in previous auctions, it would have produced prices in the $100-$150/MW-day range.

“It’s going to hit everybody,” Patton said of reliability issues, especially during winter storms.

“We can’t maintain reliability without a capacity market that functions,” he said. “We need to realize that keeping the lights on is way more important than spending a little more on capacity.”  

Patton also said stakeholders must get comfortable with MISO placing a marginal value by resource type on capacity.

“You get to a point that you have enough wind that building more wind isn’t going to have reliability value,” he said.

Brett Kruse, Calpine’s vice president of market design said he was surprised that MISO is willing to bend its demand curve after years of opposition. He said he considered it inevitable.

Kruse said a demand curve sending “investment signals” is meant to keep existing baseload generation online. He said new merchant thermal generation is unlikely to be built without developers first securing 20- to 30-year power contracts.

Peregrine Consultants President Charles Griffey said MISO doesn’t need a three-year forward market if it can develop incentives within its one-year spot market.

“The problem is do we really have that incentive in these areas?” he asked rhetorically.

Griffey said demand curved shapes will likely be a “political decision” involving a subjective reliability target, while factoring in carbon-reduction goals.  

Patton agreed that forward capacity markets are a “terrible, terrible” idea, saying they interfere with investment, fuel procurement and generator-retirement decisions.

Lisa Duffey, Cleco’s director of strategic market and fuel operation, said she wasn’t sure MISO and SPP were doing enough to make sure that capacity is deliverable to load. She said MISO’s planning doesn’t ever seem to help localized transmission constraints.

“Are we fixing the real problem?” she asked.

Patton said MISO should design its local resource zones to reflect actual load pockets. He said Zone 9, which combines East Texas and Louisiana, is the worst offender for not recognizing natural electrical boundaries.