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November 9, 2024

FERC Approves Revisions to PJM’s ELCC Accreditation Model

FERC on Friday conditionally approved a PJM proposal to revise its approach to accrediting intermittent and hybrid resources under its effective load-carrying capability (ELCC) model, a change that aims to more accurately model roadblocks to delivering capacity from those generators during peak conditions (ER23-1067).

The new rule caps the hourly output that can be incorporated in the ELCC calculation at the resource’s individual capacity interconnection rights (CIR) level and creates a transitional process where generators can temporarily receive higher accreditation while they undergo a re-evaluation of the value of their capacity contribution.

PJM’s current practice of including hourly output above a resource’s CIR rating in its ELCC analysis when setting accreditation has been the source of much of the contention over the two years and is the subject of an ongoing complaint with FERC (EL23-13). (See Stakeholders Challenge PJM in Capacity Accreditation Talks.) The approved proposal was the result of a long development process that culminated in stakeholders approval in January. (See PJM Stakeholders Endorse Accreditation Changes for Renewables.)

“We agree with PJM that reflecting a resource’s deliverable megawatts in PJM’s model of the resource’s expected output guarantees that the modeled output will not exceed the resource’s studied deliverability and aligns with the requirement that a capacity resource’s sell offer cannot be greater than its CIR megawatt value,” the commission said in its order.

In its filings, PJM stated that the shift was based on a reconsideration of the assumption that historical system conditions can be used to effectively estimate the future reliability contribution of intermittent resources. Instead, it posits that decarbonization is likely to change system conditions to a degree that the ability to evaluate future outputs and curtailments is uncertain. The revisions also change the accredited unforced capacity (AUCAP) analysis to adjust actual output to account for curtailments.

For combined resources, such as hybrids, the output of the variable component in the ELCC calculation will be capped at the overall generator’s deliverable megawatt value minus the effective nameplate capacity of the limited-duration component, such as a battery. PJM argued that the status quo risks overcounting the output of the intermittent portion of the generator and cause the combination resource’s ELCC output to exceed its deliverability.

Because the new methodology will effectively reduce the accreditation for intermittent resources and require existing and planned generators to re-enter the interconnection queue, which has been beleaguered by long review times, the revisions include a transitional process through which generators can request a higher temporary accreditation and take advantage of existing transmission headroom.

To participate in the transitional study process, the additional capacity a generator is seeking to deliver must be available without any physical modifications to the facility, and the headroom must not be claimed by another generator’s CIRs. The studies will be conducted prior to each future BRA and continue until PJM has completed the process of transitioning to the new methodology for studying interconnection requests.

The commission identified inconsistencies between the filing’s description of the transition mechanism and the proposed revisions to PJM’s Reliability Assurance Agreement (RAA). It required that the RTO submit a compliance filing within 30 days aligning the two.

Protests

The proposal originally included a requirement that generators seeking to enroll in the studies apply by March 3, but by approving the filing with an April 10 effective date, the commission extended the application time frame and encouraged PJM to consider lengthening it further should it pursue its stated intention of delaying the 2025/26 Base Residual Auction and future capacity auctions.

An association of clean energy industry groups opposed the filing, arguing that closing applications for the transition studies violates a Federal Power Act provision requiring RTOs provide at least 60 days’ notice of any proposed changes and does not provide generators enough time to determine how much additional capacity they should request. It argued that PJM should instead include a new window for applying for the transition studies prior to each BRA.

PJM responded by stating that the stakeholder process included significant discussion of the process and “more than ample notice of the timing.” It also said more than 400 study requests have been submitted, which it said is evidence that generators had sufficient time to apply.

FERC said that, “should PJM determine to make a filing with the commission to delay the 2025/2026 BRA, we encourage PJM to consider extending the deadline for submitting a request to increase a resource’s CIRs as well.”

The Natural Resources Defense Council protested the proposal on the basis that it represents undue discrimination against ELCC resources by requiring them to pay for higher transmission costs to recover the accreditation that would be lost under this proposal, when in the past thermal generators have had interconnection costs passed to load under what it describes as similar circumstances.

“PJM’s proposal does not require any ELCC resources to pay for upgrades to ensure reliability; PJM is offering ELCC resources the opportunity to request additional CIRs to increase their accredited UCAP,” FERC said. “The interconnection queue is PJM’s existing process by which all resources request and receive CIRs. Thus, PJM’s proposal is not unduly discriminatory; it simply reflects existing processes that are designed to achieve different goals.”

Clements Dissent

In opposing the filing, Commissioner Allison Clements argued that the proposal will reduce generators’ ability to deliver capacity that is currently able to be provided to the transmission system and requires them to re-enter the transmission queue at the back of the line, potentially creating scenarios in which generators that could provide their status quo capacity with minimal upgrades wait years to find that they’re now being asked to pay substantially higher transmission upgrade costs. By reducing the accreditation for both intermittent and combined resources, she said, the order risks increasing capacity costs, sending inefficient price signals and over-procuring capacity.

“In other words, owners of existing ELCC resources whose requests for a higher amount of CIRs could have already been processed at low cost find themselves sent to the back of a slow-moving line that will take years, fighting to purchase at a potentially much higher price the same capacity deliverability they could’ve already gotten, or arguably have already purchased,” Clements wrote.

She also argued that the April 10 deadline provided too little notice for generators, likely creating an “ill informed mad dash into the interconnection queue.”

“Rewarding this approach allows regulated entities to strong-arm market participants into compliance actions prior to a commission determination, meaning that proposed rules that are not just and reasonable or are unduly discriminatory will shape commercial decisions before the commission can opine on them,” Clements wrote. “While an order ultimately rejecting a proposal as not just and reasonable or unduly discriminatory would give market participants some relief from having to comply with a rule that does not past muster under the Federal Power Act, it would not return to them the time and money spent complying with the proposed unjust and unreasonable or unduly discriminatory rule in advance of the commission’s determination.”

California PUC Approves Microgrid Incentive Package

The California Public Utilities Commission on Thursday approved rules for its Microgrid Incentive Program, a $200 million effort to support the development of microgrids in communities prone to extended blackouts from wildfires, earthquakes and line outages.

The approved decision allocated funds to the state’s three large investor owned utilities — $79 million for Pacific Gas and Electric, $83 million for Southern California Edison and $17.5 million for San Diego Gas & Electric — to “build complex projects that can operate independently for extended periods and serve multiple customers in disadvantaged and vulnerable communities,” the CPUC said in a statement.

Selected microgrid projects can receive up to $15 million each.

“The Microgrid Incentive Program will provide valuable support to disadvantaged and vulnerable communities towards ensuring they are not left behind in the broader statewide resiliency effort,” Commissioner Genevieve Shiroma, who led the proceeding, said in the statement.

“These communities tend to be located in more electrically isolated areas with greater distances to essential services, experience more outages, and have less accessibility to entities with backup power. This program will also provide the funding and education many communities need to meaningfully participate in the program.”

Disadvantaged and vulnerable communities eligible for the grants include those in areas at high risk of wildfires or that have experienced public safety power shutoffs, the intentional blackouts that utilities use to prevent their equipment from starting blazes. Also eligible are locations prone to damaging earthquakes and those with lower levels of reliability because they are served by one of the worst-performing circuits in a utility’s system.

The Blue Lake Rancheria microgrid, in an area that meets all the requirements, is often cited as an example of the value of microgrids in California. It uses a 420-kW solar array and battery storage to power a hotel and casino with electric vehicle charging, a convenience store gas station and water systems used by nearby residents during frequent outages, including to keep cell phones charged. It was funded by a California Energy Commission grant last decade.

The CPUC proceeding began in 2019 in response to Senate Bill 1339, which required the commission to “facilitate the commercialization of microgrids for distribution customers of large electrical corporations” and to “develop separate large electrical corporation rates and tariffs … to support microgrids.”

Thursday’s decision also directed PG&E, SCE and SDG&E to conduct outreach and consult with potential program applicants, and to help successful applicants develop community microgrids. It requires the utilities to post handbooks to their websites within six months to “guide applicants through the program and explain how potential projects will be evaluated.”

The utilities must submit quarterly status reports to the CPUC until the funds run out.

Weaning NY off Natural Gas More Easily Mandated than Accomplished

ALBANY, N.Y. — Natural gas is in the crosshairs of New York’s decarbonization drive, but the fossil fuel will likely remain indispensable to the state’s energy portfolio for years to come, even as it contributes to climate change.

So, until the transition is accomplished, it is critical to leverage every molecule of gas as efficiently as possible, panelists argued during the April 4-6 NY Energy Summit.

Chris Stolicky 2023-04-06 (RTO Insider LLC) FI.jpgChris Stolicky, N.Y. Department of Public Service | © RTO Insider LLC

The state’s Climate Leadership and Community Protection Act (CLCPA) codified decarbonization goals, including 70% renewable energy generation by 2030 and zero-carbon electricity by 2040, while New York City’s Local Laws 97 and 154 effectively will ban installation of new gas systems in buildings starting in 2024.

And as New York’s Tale of Two Grids notes, upstate regions’ power needs are almost entirely supplied by renewable resources, while downstate is run almost exclusively by fossil fuels, particularly natural gas.

“New York was a pioneer in using gas, and so it is no surprise that it is now pioneering aggressive climate goals that reduce methane,” Chris Stolicky, chief of gas system planning and reliability at the New York Department of Public Service, said during his “Future of Natural Gas” presentation.

“The catch to this is that if you lose gas service, it’s a very big deal” because it “delivers three times as much BTU content and energy to customers than other resources,” so if New York wants to “offset that heating load with electric versus natural gas, [the state] needs to deliver three times as much energy,” Stolicky said.

Cooperation is Key

Natural gas is targeted for its global warming effects, both from methane leaks before combustion and carbon dioxide emissions during combustion. But as Stolicky noted, New York continues to rely on it for more than 40% of its energy needs, and the United States has become the largest gas producer in the world.

On top of that, there was a widespread push to replace oil-burning equipment with cleaner-burning gas until relatively recently. New York now “wants to stop that train … and find a better way to generate energy because there’s a lot of emissions and impacts,” Stolicky said.

This is not expected to be easy, particularly in the densely populated downstate regions.

Therefore, “as the last firewall” between policymakers and consumers, Stolicky and his team act as the “gas ISO for New York,” and look to balance system reliability and affordability with environmental concerns by bridging cooperation between stakeholders.

“A well planned and strategic transition of the gas system will require coordination across multiple sectors,” he said.

Stolicky said an integrated planning process involving customers, NYISO and state agencies enables gas utilities to forecast peak demand, keep costs low without compromising reliability, and educate ratepayers about an industry whose operations influence their daily lives but has “not always been transparent.”

Stolicky said his agency remains committed to New York’s decarbonization, but there are challenges ahead and stakeholders need to “buckle down and work hard collectively” to overcome them and bring the state to its net-zero goals.

New York utilities argue they are well positioned to tackle these challenges because of their existing network of assets, extensive knowledge about grid operations, and ability to invest in new technologies to replace natural gas.

Leverage Every Gas Molecule

During the Transmission & Distribution Plans & Investment panel, moderated by RTO Insider’s Rich Heidorn Jr., Christopher Raup, vice president of energy policy and regulations at Consolidated Edison (NYSE: ED), and Tom Vaccaro, director of transmission business development at National Grid (NYSE: NGG), made their case for why utilities are well positioned to help New York’s transition.

Both panelists emphasized how state utilities committed to collaboratively decarbonize through the Coordinated Grid Planning Process (CGPP). They said that the plan will maintain reliability, expedite renewable development and deployment, keep utilities competitive and not hurt ratepayers.

The details are not finalized, however. (See NY Utilities’ Proposed Grid Planning Process Gets Tepid Reception.)

Leaving “no stone unturned” the CGPP plan offered by New York’s utilities would operate via a “meaningful iteration” process that integrates stakeholders while “striking a balance between coming up with new information and getting [interconnection] processes done as quickly as possible so that [stakeholders] can iterate again,” said Vaccaro.

New York has a “high voltage” problem, said Vaccaro, explaining that the grid is “running at 345 kV, which is very high compared to what you would typically see for bulk power at the utility distribution level.” The utilities’ CGPP proposal would solve this issue by integrating transmission planning at all grid levels so utilities “can build things for customers that are less expensive.”

Additionally, after Superstorm Sandy, utilities have actively worked with state agencies and other stakeholders to develop climate modeling that predicts extreme weather impacts on the electric system, according to the panelists.

Utilites “take lessons from climate change vulnerability studies and reflect those in the infrastructure that [they] build out and operate,” said Raup.

“All of us utilities have a shared [decarbonization] vision with the state and NYISO,” and the cooperation initiated by the CGPP “hopefully removes some roadblocks and expedites these processes,” Vaccaro said.

Vaccaro fielded a question about how the state’s utilities are strategizing fossil fuel infrastructure as the state presses to make it obsolete.

“We’re not going to be able to do everything at once” but will “leverage the remaining life out of our gas system” since New York’s electrification may face future challenges, he said. Utilities plan to “use [gas] equipment for as long as [they] can before transitioning out.”

Raup added that hydrogen could be used in existing gas infrastructure after 2040 and “could help fill the valleys when the sun isn’t shining, or the wind isn’t blowing.”

Hydrogen: A Natural Gas Substitute?

Hydrogen is still in development as a clean and economical energy source but likely has a future in New York as the technology improves.

Green hydrogen was frequently cited “as a tool to reduce greenhouse gas emissions” in the Climate Action Council’s Scoping Plan.

Pete Budden 2023-04-06 (RTO Insider LLC) FI.jpgPete Budden, Natural Resources Defense Council | © RTO Insider LLC

More recently, the state, as part of the seven-state Northeast Regional Clean Hydrogen Hub, applied to be designated as a national hub for hydrogen.

“I envision hydrogen infrastructure across the U.S. with pipelines in different municipalities all shifting their waste to go to hydrogen gasification,” Joe Bushinsky of the Regional Hydrogen Infrastructure Development at Mitsubishi said during the Hydrogen Hubs: Financing, Revenue Structures & Incentives panel.

Introducing this technology to scale “is a challenge, but it is doable” he said. “There is a market for [hydrogen] but a lot of things have to fall into place.”

One potential opportunity, Bushinsky said, “is to take waste and instead of putting it into landfills and waiting years for it to produce renewable natural gas to instead move it to syngas to produce hydrogen.”

Pete Budden, a green hydrogen advocate with the Natural Resources Defense Council, tempered expectations, saying hydrogen “is an incredibly useful and important tool in our decarbonization toolbox,” but “can be a distraction from more cost-effective solutions.”

“Hydrogen is an indirect greenhouse gas,” Budden said, referring to how atmospheric leakages prevent methane decay, so it “should not land into gas distribution networks” because that blending is “where we are most worried about leaks.”

Jessica Waldorf 2023-04-06 (RTO Insider LLC) FI.jpgJessica Waldorf, N.Y. Department of Public Service | © RTO Insider LLC

Michel Delafontaine, president of Alternative Aviation Fuels, agreed, saying “blending is not going to be the project that drives these infrastructure demands” and hydrogen’s best application will be decarbonizing transportation or energy-intensive industries such as steelmaking.

But he pointed out that some utilities, SoCal Gas for example, have been studying how to safely blend hydrogen into their gas networks.

“There are opportunities for these infrastructure projects” to help gas utilities decarbonize since it can “act as an enabler” to defer consumer costs by expanding capacity, Delafontaine said.

Moderator Michelle Detwiler, executive director of the Renewable Hydrogen Alliance, added that Hawaii Gas has been “blending hydrogen into their syngas residential distribution systems at about 20% for 46 years with no deleterious effects.”

The push to phase out natural gas as quickly and completely as possible in New York is countered by the need to maintain its infrastructure as long as needed.

Jessica Waldorf, chief of staff and director of policy implementation at the Department of Public Service, touched on this during her presentation. “There are many paths to achieving the outcomes envisioned in the climate act,” she said, and a “one-size-fits-all approach is unlikely to meet the diversity of needs across the state.”

Climate Roadmap Urges Oregon to Step Up Actions

A new report from Oregon’s Global Warming Commission (OGWC) says although the state is a long way from meeting its 2035 greenhouse gas reduction target, it should nonetheless advance that goal by five years. 

The Oregon Climate Action Roadmap to 2030 says the state is expected to meet its goal of reducing economywide GHG emissions to at least 45% below 1990 levels by 2035, but cautions that “there is a great deal of work that needs to be done before then.”

And despite the workload, the OGWC calls for the state to accelerate its 2035 GHG-reduction target to 2030 because “the best available climate science indicates the need to go further and faster to avoid the worst impacts of climate change.”

“The new Roadmap to 2030 reflects that urgency and demonstrates that it is not only feasible to achieve the state’s 2035 goal by 2030, but doing so will also provide substantial economic and health benefits for Oregonians,” OGWC Chair Catherine Macdonald said in a statement accompanying release of the report on Friday.

Oregon’s GHG targets are set out in Executive Order 20-04, which former Gov. Kate Brown (D) issued in 2020 after Republican state senators walked out of the legislature to prevent a vote on a bill establishing a cap-and-trade program for the state. The order directed state agencies to implement policies to help reduce GHG emissions to at least 45% below 1990 levels by 2035 on the way to an 80% reduction by 2050.

The roadmap is the product of the Transformational Integrated Greenhouse Gas Emissions Reduction (TIGHGER) project, a yearlong effort that convened the OGWC, state officials, consultants and various stakeholders to address the fact that Oregon’s existing planned actions on climate change would not be sufficient to meet state targets. Those actions include three major efforts being led by the state’s Department of Environmental Quality, including: 

  • implementation of the Climate Protection Program (CPP), designed to drive down emissions from stationary sources, transportation and natural gas by setting declining caps on GHGs; 
  • an expansion of the Clean Fuels Program (CFP), which will decrease the carbon intensity of fuels sold in the state by 25% by 2035; and
  • a program to reduce GHG emissions from electricity generation 80% by 2030, 90% by 2035 and 100% by 2040.

Other state actions include the Heat Pump Rebate Program, the Community Renewable Energy Program and adoption of California’s Advanced Clean Cars II and Advanced Clean Trucks rules. (See Groundbreaking California Clean Truck Rules Win EPA Waiver.)

Despite existing efforts, Oregon’s 2020 GHG emissions totaled 58 MMTCO2e, 13% above its target of 51.3 MMTCO2e (a 10% reduction from 1990 levels). Emissions rose further, to 61 MMTCO2e, in 2021, 19% above the 2020 goal. The roadmap “is aimed at ensuring Oregon does not miss its next GHG emission reduction goal,” the commission said.

Relying on analysis from the TIGHGER process and OGWC discussions, the roadmap recommends six “overarching strategies for maintaining and increasing Oregon’s climate action ambition,” including:

  • supporting “robust and continuous implementation” of the state’s existing climate programs and
     regulations, such as the CPP and CFP;
  • adopting updated GHG goals consistent with the best available science;
  • advancing a set of new climate actions based on the TIGHGER analysis to help the state accelerate its GHG reduction goal to 45% below 1990 levels by 2030, rather than 2035;
  • supporting “further study and analysis to continue to guide effective climate action over time;”
  • strengthening “governance and accountability” to ensure the state meets its targets; and
  • positioning the state to “take full advantage” of federal money directed at climate action.

‘Scientific Imperative’

The roadmap fills out those strategies with 26 “sub-recommendations” containing more concrete actions.

“For example, policies supporting the development and availability of transmission could help alleviate a potential barrier to achieving the clean electricity targets in HB 2021,” the report says.

The roadmap also urges the state to ensure that programs benefit environmental justice communities that suffer a disproportionate burden from the impacts of pollution.

Some of the most challenging recommendations fall under the second strategy that seeks to update the state’s GHG goals. They include clarifying that Oregon’s policy is to pursue GHG reduction actions consistent with the goal of limiting the global temperature rise to 1.5 degrees Celsius. That would entail reducing emissions to at least 45% below 1990 levels by 2030, followed by reductions of at least 70% by 2040 and 95% by 2050. 

“[A] 2050 goal of 95% below 1990 levels would be consistent with the leadership our neighbors to the north [Washington] and south [California] are showing, better reflect the existing ambition of some of Oregon’s key climate programs, and result in the strongest emissions reductions — which is ultimately the scientific imperative,” the report says.

Under the third strategy — advancing new climate actions — the OGWC lists an extensive set of recommendations that include a 50% improvement in energy efficiency of industrial facilities not covered by the CPP by 2050; exceeding Advance Clean Truck targets by 2035; boosting rooftop solar output to 16.3 TWh by 2035; increasing Amtrak ridership; and implementing congestion pricing on highways in metropolitan areas.

To improve accountability for achieving GHG targets, the report calls for an increased role for the OGWC itself. They include boosting dedicated staff by one full-time equivalent (FTE) from the current 0.3 FTE; expanding the list of OGWC’s non-voting members to include representatives from additional state agencies, such as the economic development agency Business Oregon, the Department of Fish and Wildlife, and the Oregon Health Authority; and expanding the OGWC’s voting membership to include a youth representative and an expert in environmental justice.

The roadmap also calls for additional funding for the OGWC to create and maintain a dashboard and clearinghouse for tracking climate action, emissions and carbon sequestration data.

The OGWC additionally recommends that Oregon agencies coordinate their efforts in pursuing funds from the federal Infrastructure Investment and Jobs Act and Inflation Reduction Act.

“The amount of federal funding that is coming available for climate, clean energy, and natural and working lands projects is unprecedented and presents a huge opportunity for Oregon,” the roadmap says. “Many of these programs will be competitive in nature — meaning Oregon will be competing with other states for limited funds. Oregon will need to be ready to apply for these funds with credible, well thought out programs and projects.”  

Report Flags Gaps in Scientific Knowledge of OSW Effects

A new report by two federal agencies and a fishing industry group concludes there are major gaps in scientists’ understanding of offshore wind power’s impact on marine ecosystems.

The report focuses on U.S. waters, where only a handful of turbines now stand, but draws in part on knowledge gathered in other countries, where OSW farms have been operating for years.

Opponents of offshore wind development have criticized the rush to build without a complete understanding of the impact on fisheries before research is complete, or even begun. (See Fishing Impact Seen on SouthCoast Wind Project and NJ Outlines OSW Research Projects amid Ocean Enviro Anxiety.)

OSW supporters counter that the new source of large-scale carbon-free electricity is crucial to addressing climate change.

But neither of these opinions are in the report; instead, it is a straightforward presentation of what is known and unknown at the start of the OSW era in the U.S.

Multiyear Effort

The report by the Bureau of Ocean Energy Management (BOEM), the Northeast Fisheries Science Center of the National Ocean and Atmospheric Administration (NOAA) and the Responsible Offshore Development Alliance (RODA), is an outgrowth of the groups’ 2019 memorandum of understanding to collaborate on the process of OSW development on the U.S. Outer Continental Shelf.

They have been working on the report since their Synthesis of Science workshop in October 2020 drew more than 550 participants from a wide range of backgrounds and disciplines.

The analysis deals primarily with fixed-turbine technology; floating-turbine technology, which is less mature, will be addressed in a separate project led by RODA.

The 388-page report lists existing knowledge; known gaps in knowledge; commercial and recreational fishing industry opinion; and recommendations for future study on the impact on habitats, oceanographic processes (changes in temperature or salinity), ecosystems and fisheries.

The report examines the noise and disruption of construction, the lesser noise of operations and the oceanographic effects of turbine blades spinning above the surface. The impact on individual species — from plankton and small fish to the commercially important groundfish and large marine mammals — is not documented. Whether OSW development will have cascading effects up and down the food chain is also unknown.

As a result, the report makes no predictions on the effect on the fishing industry or waterfront communities whose culture and economy are linked to the fisheries.

The report does predict that blue mussels will colonize the tower foundations and cites limited evidence of decreased squid abundance near the five towers of the Block Island Wind Farm, the first commercial OSW project in the U.S. Pile driving noise is known to cause death or hearing injury in fish, it notes.

Seeking Knowledge

RODA has criticized the OSW development process repeatedly, not least by challenging BOEM’s approval of the Vineyard Wind I project in federal court in September 2021.

But RODA’s March 30 announcement of the report’s release is clinically neutral, with no criticism leveled or demands made.

RODA Research Director Fiona Hogan told NetZero Insider that there was no messaging in the report because its purpose was to compile for the first time a summary of what is known and unknown about the ecological effects of offshore wind.

“We’re unaware of any effort that has looked at the entire range of impacts in one place,” said Hogan, a co-author of the report.

The report can serve as a resource for anyone who wants to learn more, Hogan said. But it states bluntly that an enormous amount of research is still needed to build a better understanding of OSW’s impact on the ocean and its fisheries.

The report notes that time is limited, as the ability to gather data after construction could be impaired. Aerial surveys may be impaired, particularly on cloudy days, because aircraft must stay well above the rotor blades; surveys from the surface may be limited by low-swinging blades; and subsurface surveys may be impaired by the new underwater infrastructure.

It implies the opportunity has passed for a regional science plan that could have provided an understanding of OSW’s cumulative impacts before construction starts.

“Our ability to detect the impact is impacted,” Hogan said. “That’s why we need ongoing monitoring and research.”

The report takes note of the fishing industry’s concerns over BOEM’s approach in analyzing projects on an individual rather than cumulative basis. “The environmental and economic effects will not be isolated, and fishing communities have suggested the scale of analysis should match that of fisheries and ecosystem management practices,” the report said. RODA made the same point repeatedly in a motion for summary judgement filed in late 2022 in the Vineyard Wind case.

BOEM is the lead agency in the effort to reach President Biden’s goal of 30 GW of OSW by 2030.

NetZero Insider asked BOEM for response to the report, and asked whether it planned to make any changes in its approach as a result. BOEM responded that it had asked the National Academies of Sciences, Engineering and Medicine to form the Standing Committee on Offshore Wind Energy and Fisheries to encourage the kind of dialogue that began at the 2020 workshop.

NOAA had no comment beyond a March 30 news release quoting Andy Lipsky, head of the wind energy team at NOAA’s Northeast Fisheries Science Center and a co-author of the report:

“We are pleased to have been a part of this project and look forward to working with our partners on its next iteration, a series of workshops focused on fisheries and floating offshore wind energy. This collaboration was a great success and truly helped us as we developed a joint survey mitigation strategy with the Bureau of Ocean Energy Management. It also helps us define and begin developing the new kinds of monitoring required to continue our long-term data streams on ocean life as well as needed research on how offshore wind energy changes marine habitats and fisheries.”

IPF Panel: MSSC Limits Could Cut OSW Power Coming Onshore

BALTIMORE — Offshore wind turbines can — and in the coming years, will — produce thousands of megawatts of electric power, which is way more than the onshore transmission system is currently able to absorb, according to Bill Magness, senior principal consultant at DNV.

States and offshore developers “want to see the most bang for the buck. … [They] want to see the maximum transfer into the system of those offshore resources,” Magness, the former CEO of ERCOT, said during a panel at the Business Network for Offshore Wind’s recent International Partnering Forum (IPF). “Moving into the onshore grid is where the rubber really hits the road, or the water, or whatever it’s hitting.

“The onshore grid is where the load is … where the ratepayers are, and the onshore grid is where an extremely sophisticated, complex, several-decades-old, AC-based system lives … [with] limits on reliability and limits on interconnections that have to be honored,” he said.

The most severe single contingency (MSSC) is one of those limits, setting a maximum amount of reserve power a balancing authority is responsible for in the case of a sudden, large outage. For ISO-NE, the limit is 1,200 MW; in NYISO, it’s about 1,310 MW; and for PJM, it’s 1,500 MW — all of which “are suboptimal from the perspective of the technology that you want to bring onshore,” Magness said.

Reflecting the integral role it will play in offshore development, transmission was a major theme at IPF, with its own track of focused panels looking at the solutions that will be needed to efficiently and cost-effectively bring offshore power on shore. Meshed HVDC networks, as opposed to individual radial lines, have been identified as the most optimal way of connecting offshore turbines to onshore substations. (See OSW Developers Look to Europe on Meshed HVDC Tx.)

But the MSSC issue “is one that highlights a number of other issues that we’re going to be facing,” Magness said. To begin with, reliability standards based on the MSSC “were not written with HVDC in mind. … People are finding that, well, maybe the single contingency breach for HVDC is different than we thought.”

The MSSC is not itself a limit, he said, but NERC uses it to set the reserves a BA is required to have, purchased and ready to go in such contingencies.

“If you lose certain generation, you will have to make that up within 15 minutes; that’s the standard requirement,” said Gaurav Karandikar, senior manager for reliability analysis and technical services for SERC Reliability. “The balancing authority can actually study their system and determine that value … and that drives how much reserve you are going to carry.

IPF Transmission Panel 2023-03-30 (RTO Insider LLC) Alt FI.jpg

Talking transmission at IPF were (from left) Sheri Lauten, National Grid Ventures (moderator); Bill Magness, DNV; Shahil Shah, NREL; Gaurav Karandikar, SERC; and Peter Shattuck, Anbaric. | © RTO Insider LLC

“The other aspect is that there is a 90-minute limit, where after that first contingency [where you] have used your contingency reserve,” Karandikar said. “You have to re-establish that contingency reserve within the next 90 minutes, so you’re ready for the next contingency.”

Factoring onshore wind into those equations may mean looking at the issue “in a more flexible way, in a more targeted way that can manage … the larger-end feeds that are coming onshore,” he said.

Echoing Magness, Shahil Shah, a senior engineer at the National Renewable Energy Laboratory (NREL), said the MSSC issue is complex; it’s part of the problem but also a potential solution. The current MSSC limits don’t “allow us to go for big cables that are currently available,” he said.

“We see many projects where cables are coming from the same lease areas going to the same substations, but there are multiple of them,” Shah said. The way forward will involve designing HVDC transmission that can quickly isolate and recover from outages or other contingencies, he said.

Super-fast, super-reliable DC circuit breakers and multivendor interoperability will be needed, as well as revised, more sophisticated MSSC limits, he said.

“We need to coordinate the reliability standards and the resource standards together,” which will also require coordination between regulators, Shah said.

Coming in with a developer’s perspective, Peter Shattuck, president of Anbaric Development Partners’ New England projects, called for an incremental approach to the tangled issues involved in MSSC limits.

“It’s really hard to navigate the challenge of finding the most cost-effective solution that’s responsive to signals we’re getting from procuring entities during a period where these myriad questions and challenges that have been laid out are not resolved,” Shattuck said.

Magness agreed that with new procurements coming, “it is really essential that we start to inventory what these [transmission] issues are, identify them and pick the ones that are most important and try to start solving them.”

A 2-GW Standard

The meshed, HVDC model is well established in Europe, where most recently TenneT, the transmission system operator in the Netherlands and parts of Germany, announced its plans for a standardized offshore transmission platform with 2-GW certified cable. The company intends to deploy this new system on at least 10 projects, a scale that could have significant impacts for offshore supply chains, Shattuck said.

“When there are tenders out there for 10-plus 2-GW systems, that’s where the supply chain is going to go,” he said. “So, if you want something else, if you want a customized solution or even kind of tweaking the 2-GW design to address some of these [MSSC] issues, that’s going to have implications for costs and the timelines for bringing [a] project online.”

At the same time, a standard 2-GW cable could provide considerable economies of scale, he said. While New England currently has about 6 GW of offshore wind in development, Shattuck cited an industry analysis that an additional 24 GW of projects or more will be needed to meet the region’s climate goals.

“If you’re doing that with 2-GW systems, then you’re going to need 12, and if you’re doing it with 1,200-MW systems, you need 20,” he said.

ISO-NE has taken the first steps toward resetting its MSSC from 1,200 MW to 2 GW, with a recent letter to its Joint Planning Committee with NYISO and PJM, asking for a feasibility study on the change.

“As the region moves forward with the interconnection of large-scale renewables, such as offshore wind resources, project developers may identify proposals larger than 1,200 MW,” Brent Oberlin, ISO-NE director of transmission planning, said in the March 27 letter. “The 1,200-MW limitation could constrain an otherwise optimal interconnection design. …

“Depending on system conditions in PJM and NYISO, this limit can be raised in real time to a maximum of 2,000 MW,” he said.

Magness also pointed to NYISO’s ongoing exploration of dynamic scheduling of reserves, which could allow New York to import more clean energy to meet its emission-reduction goals of 40% below 1990 levels by 2030 and no less than 85% by 2050. (See Study: NYISO Dynamic Reserves Could Lower Congestion, Costs.)

Panelists also said that, rather than trying to change any NERC standards — which would involve what Magness called a “baroque” process ― there are opportunities for regional changes that could address the MSSC limitations. Such solutions could “address reliability concerns and optimize the technology,” Magness said.

Low-hanging Fruit

NREL’s Shah argued that grid operators’ mandated levels of reserves are often higher than needed, “so we should be able to inject more power during those times. … That’s low-hanging fruit, just a slight modification in the standards.”

Multiterminal offshore grids might offer another option, assuming that not all terminals would be operating at full capacity, he said. “If the capacity factor is diversified, then also there is another way to make sure that we are within limits, but at the same time we are allowing points of high injections.”

Having 2-GW lines also could provide “head room” for capacity in the event of outages, Shattuck said. For example, with three 2-GW lines operating with a capacity of 1,500 MW each, if one line trips off, the other two lines can each pick up 500 MW of capacity, “so the system only loses 500 MW, well below the current contingency,” he said.

“The ability to pick up extra power just increases the more lines that are connected to shore and networked offshore,” Shattuck said. “So, in a way, the challenge is just getting over the near term … and getting these first projects built. In a way, the offshore grid becomes a solution to the constraints of the onshore side.”

Regional solutions can also be more finely tuned, Magness said.

“The regions that have seen more resources, wind and solar systems, some of what they have realized is … you’ve got to slice this thing a lot more finely than you used to,” he said. “You need to procure reserves during demonstrated hours and minutes when you need them, and you don’t need to procure reserves at the same levels when you don’t.

“You start to see what those patterns are, what seasons of the year in your particular region require [you] to have more reserves on hand, and you’re able to run the system more efficiently based on everything you’ve got on the system,” he said.

Such procurement strategies could also allow grid operators to take advantage of the “extremely fast response times” batteries can offer, he said.

Both Karandikar and Shah said that the foundation for such changes will be good research and good computer models, supported by industry.

“If you’re looking or asking people to come up with a realistic limit, we should be able to make sure that we are providing them with good information,” Karandikar said. It is incumbent upon industry to ensure “planners have enough tools,” he said.

“It will be possible that we can maintain reserves offshore, provided we are able to forecast accurately how much capacity is available,” Shah said, noting that NREL has run demonstrations of such forecasting. “It is possible if we have a coordinated design for the offshore wind generation.”

Magness sees a range of benefits for meshed HVDC offshore transmission and more flexible approaches to MSSC limits, including less curtailment and opportunities for redispatch, “being able to move the power around through software systems in much more effective ways,” he said.

The task ahead is to think “in terms of building out a network not only to optimize the amount of wind that comes into the system but provides the maximum controllability, flexibility benefits that we can get from HVDC technology,” he said.

“How do we imagine them in a world where we have a grid that serves load onshore but also a grid that doesn’t have load sitting next to it in the ocean?” he said.

New York 2023: Growing Pains for the Energy Transition

ALBANY, N.Y. — The 2023 New York Energy Summit last week focused on the financial, regulatory and technology landscape in the state as it presses forward with a hugely ambitious, complicated and expensive energy transition.

Opportunity tempered with challenge and uncertainty was a recurring theme in the comments of dozens of panelists and in the questions posed by scores of attendees of the April 4-6 summit.

New York’s leaders are still wrangling over key policy details, and federal guidance on how to leverage key tax incentives for clean energy finance is incomplete.

Meanwhile, despite some streamlining, the development process is still often slow and difficult in New York, and local opposition can be fierce. The grid interconnection process continues to be a bottleneck, as well.

But a confluence of factors — vision and opportunity backed by leadership and funding to make it reality — is present in New York in 2023.

Nick Addivinola, of community solar developer Nautilus Solar, observed that money is not a problem, even amid high interest rates and inflation.

“There is certainly more capital chasing projects today than ever,” he said. “There’s more capital than projects.”

The 19 presentations at the conference included discussion of New York’s landmark climate law, efforts to decarbonize buildings, grid resilience, and financing all the work that the state needs or wants to see accomplished.

High Needs

A frequent talking point at the summit was the large number of skilled workers who will be needed to carry out New York’s energy transition — more than 200,000 by 2030, according to a state estimate — and how far short of that the present workforce is.

Michel Delafontaine, president of Alternative Aviation Fuels, said the timelines specified in various state and federal laws and guidance “seem to be long, but it’s short. In terms of workforce development, we’re looking at a turnover of three to four years to form and shape folks that know what they’re doing in many aspects — electrical, pipefitting, number-crunching, legal and all the aspects of project development — and we’re short of them.”

“I can testify to that aspect,” he said. “We’re short of workforce.”

Jeffrey Andreini of Crowley Wind Services said it’s a topic that comes up often in discussion of offshore wind. “What I tell people all the time is you can have the all the assets you want, you can have all the [waterfront construction and maintenance] terminals that you want, but if you don’t have anybody that’s going to run a vessel, going to be able to do the logistics on the terminal, guess what? Nothing’s going to happen.”

Richard Lawrence of the Interstate Renewable Energy Council said this reality is sinking in as more projects go from concept to execution.

“In the 20 years I’ve been working on this, I’d say the last year has really been the first time I’ve seen companies working in this space really recognizing the challenges that it takes to develop the workforce. It’s coming up now as certainly in the top three of limiting factors to actually getting to our goals and building these projects out.”

He added: “We’re competing against every other sector that’s out there that’s looking for workers.”

The Inflation Reduction Act of 2022 recognizes this need, Lawrence said. He called it one of the first federal incentive/policy packages with labor and workforce development provisions baked in.

Gary McCarthy, who has pressed the Smart Cities technology initiative in his dozen years as mayor of Schenectady, said more emphasis needs to be placed on the value employees bring to an organization than to their sheer numbers.

“We’re looking for quantity now; everyone has a demand for employees,” he said. “It’s hard sometimes to step back and focus on quality; how do you do that outreach? How do you do that in a systematic way of building the rapport, getting the message and then creating the opportunity?”

New York law requires that more than a third of state spending on the energy transition benefit disadvantaged communities, and a main strategy to accomplish this will be training and employment opportunities — which are easier to mandate than achieve.

“I think the key piece here is to have really authentic organizations that have the trust of local communities partner with entities that have something to offer,” said Adam Flint of the Network for a Sustainable Tomorrow. “Transferring resources into disadvantaged communities rather than doing everything from the outside, actually hiring people to help build these programs, is a really good move.”

The clean energy sector also butts up against a multigenerational shift away from the skilled trades by a significant portion of American society, and it has trouble competing for the attention of young people entering the workforce amid the allure (and salaries) of the computer technology sector.

Both challenges are real, panelists said, but can be overcome.

The skilled trades should be introduced as a career option to children as young as 10 to 12, midway through their schooling, panelists said, and for those who are graduating now, clean energy should be framed as an opportunity to become one of the early experts in a new economy.

Also, Big Tech is currently laying workers off by the thousands, while clean energy is hiring by the thousands, Lawrence noted.

Andreini pointed to the optics of recruiting young adults to help save the planet. “We’re cooler,” he said. “At the end of the day, you’re talking about an energy revolution right now. That’s really what’s going on. I tell adults that, and they get excited. It’s got to be about more than just money.”

Major Projects

Houtan Moaveni, executive director of New York’s Office of Renewable Energy Siting, was interrupted by the only spontaneous round of applause during the summit when he said his office — a recently created entity — has issued more final siting permits in the last two years than were issued in the preceding nine years. Each took only six months on average.

Darren Suarez of Boralex later qualified that record: ORES, which works with projects rated at no less than 25 MW, moved much of the review process outside the formal permitting procedure. Including pre-permitting work, the overall time involved is still lengthy.

But that procedural standardization and streamlining has been the beneficial result of the Section 94-c law under which ORES operates, he said.

“It has the appearance of being faster, but I think the big thing for developers is it’s more certain. You know spending the money — if we do the right thing; we meet the objectives; we meet the standards — we’ll get the permit.” That was not always the case with Article 10 permitting, which 94-c supplemented, he said.

One of the biggest initiatives in New York is not in the state, but in federal waters off its coast.

Gregory Lampman, director of offshore wind at the New York State Energy Research and Development Authority, said the state’s goal for offshore wind is 9 GW of installed capacity by 2035, but the OSW program folds in much more than the flow of electrons from ocean to land: It seeks to create a local manufacturing supply chain and the supporting infrastructure; develop a workforce; and coordinate transmission needs with NYISO while striking a blow for environmental justice and benefiting disadvantaged communities.

The goal is a new ecosystem with spinoff benefits.

“We’re trying to empower the whole of manufacturing capacity in the state of New York,” while simultaneously competing with neighboring states for finite resources and collaborating with them to expand availability of those resources, Lampman said.

And how is that working out with the 27 OSW leases up and down the Atlantic Coast?

“We probably are far short of where we need to be, but we are moving forward because there are economic pressures to develop that supply chain,” said Jim Bennett, a senior adviser at the U.S. Bureau of Ocean Energy Management.

He said BOEM’s focus is now transitioning from leasing to project review and approval.

“In the past three years, we’ve doubled the number of people we have on board, which for a federal agency is pretty impressive, but during that same time, our workload has increased fivefold,” Bennett said.

With the expansion of variable wind and solar power generation, New York needs a large amount of energy storage capacity: It has set a near-term goal of 6 GW, the most of any state, but eventually will need significantly more, some of it the long-duration type that is not yet technologically mature.

This, along with the domestic manufacture incentives of the IRA, could create a new industry sector in New York, said William Acker, executive director of the New York Battery and Energy Storage Technology Consortium.

“This is going to be a real catalyst to grow the economy in New York state,” he said.

In the wake of the supply chain disruptions of 2020 and 2021, there has been great interest in domestic manufacturing, said Michael Slattery of Agilitas Energy. “I can’t speak to the precise amount of batteries that will come into New York, but I think New York is very well positioned — as is any state that has a large industrial base and a hefty demand for the output.”

Slattery said he might be more pessimistic than most on the subject, but he expects domestic demand to outstrip domestic production for three to five years.

“It is a huge, huge logistical challenge to get these factories built,” he said.

Acker touched on a subject he has raised before: The present structure of New York’s electricity market makes large-scale energy storage uneconomical.

“The new programs that the state is bringing forward might level that playing field, but right now there isn’t really much traction,” he said. “It was mentioned earlier: We have great goals in this state, but actual deployed projects at the bulk level have been pretty minor.”

Hurdles and Hiccups

Tens of thousands of megawatts of clean energy capacity is on the drawing board in New York state, but many projects will never advance beyond that stage. This divide was a frequent topic at the summit.

Panelists touched on the long and winding road that connects inspiration and execution in New York state government, as competing interest groups delay or reshape the laws and regulations needed to bring grand goals such as decarbonization to reality.

New York’s landmark Climate Leadership and Community Protection Act — which set many of the goals the state and its energy sector must now reach — was signed into law nearly four years ago but is still mired in planning and sometimes heated debate.

State leaders are fond of pointing out that the CLCPA mandates 70% of the state’s power come from renewable energy by 2030, and that the project already in NYISO’s interconnection queue would bring the state to 66%. But some of those projects will never break ground.

“Projects haven’t been built for a variety of reasons. One of those certainly is interconnection,” Boralex’s Suarez said.

“We look at what’s in the queue now, [and] we actually see all the projects the state would need to meet, basically, its objectives. A lot of those projects won’t come to fruition for a variety of reasons, some of them as a result of timing or economics, or sometimes they’re purely speculative. Sometimes some developers may have more than one project that they’re putting in multiple interconnection queues.”

NYISO is trying to speed up the process and reduce some of the speculative activity, Suarez said, but the volume of applications is unprecedented, and the ISO is not set up for it. The most recent Class Year was one of NYISO’s largest ever, he added, and many projects had to go to FERC to seek additional time to get into it.

Moderator Ingo Stuckmann, of the Zero Emission Think Tank, asked his panel about those economic challenges, such as triple-digit price increases for substations and multiyear wait times for transformers.

Suarez said the long lead time between contracts being signed and work starting on projects proved harmful in 2022. “There is a real disconnect at this point between what the expectations were three years ago and what the reality is now, and unfortunately we’re confronted with that reality.”

Marguerite Wells of Invenergy said, “I think you see that too in the conclusion of the last [NYISO] Class Year, where half of the projects rejected their cost allocations, which means they’re out of the Class Year, and they’re either going to shut down or going to have to go through a new Class Year and hope for a better cost allocation.

“I think that’s a really significant indicator of how … these costs are impacting project economics,” she added.

Moving Forward

New York has a strong home rule tradition, and while some authority to approve renewable energy projects has been moved to the state level, local support remains important to the clean energy transition.

Winning hearts and minds is apparently something many of the panelists have put a lot of thought into; they offered the audience numerous suggestions on building community support.

Job creation is often touted by energy developers, but that is not a compelling argument to the local residents who stand up at a town hall meeting and say they just do not want to look at a solar array, said Amy McDonough of New Leaf Energy — particularly given that most of the jobs created are temporary construction positions.

“The bigger picture — what this renewable energy economy means to the state, not just this project in their town, but this project and the next project and the next project — that kind of messaging and education could potentially be helpful,” she said.

White Plains Mayor Thomas Roach said building that city’s large community solar program relied on the help of organizations trusted in the community, such as El Centro Hispano.

“They actually had volunteers entering people into the system so they could take advantage of the discounted electricity because a lot of people are intimidated by the process,” he said.

That type of outreach can be important with something like community solar, which may sound suspiciously like a scam to someone who receives a cold call solicitation, said Sandhya Murali, co-founder and COO of Solstice.

Suarez threw in a plug for expanding New York’s transmission grid, which would make it possible to site renewable energy in more of the state, and not overwhelm a relatively small number of communities with solicitations just because interconnection is possible there.

“Increased transmission can actually increase social acceptance to some of those projects,” he said.

Wells suggested focusing locally instead of globally, emphasizing economic development rather than climate change, “in terms of the renewable energy industry committing to the communities in which it works.”

As is often observed, there are two New Yorks: New York City is densely populated, heavily Democratic and unable to host a meaningful amount of clean energy generation. Beyond the New York City suburbs, most of the state is more conservative, less densely populated and has a much lower median income.

The open space upstate is ideal for solar farms and wind farms spread across thousands of acres, but many upstaters resent having to look at power lines, wind towers and solar arrays.

“In a lot of these communities, climate change doesn’t exist in the minds of many constituents,” Wells said. “So, I don’t talk about climate change as a driver for my work; I talk about economic development. Because it is the other half, and the money that these projects generate is very significant in terms of making a difference in the lives of upstate communities that don’t have a lot of other revenues.”

Public Service Co. of New Mexico Joins WRAP

Public Service Company of New Mexico (PNM) said Friday it has joined the Western Resource Adequacy Program (WRAP), expanding the reliability program’s footprint in the Desert Southwest and bringing the number of participants to 22 across the Western Interconnection.

WRAP also received formal participation agreements last week from two Washington utilities, Seattle City Light and Snohomish County Public Utility District. Both are participants in the program’s current non-binding phase, a precursor to a binding phase in which member utilities can be penalized for falling short of their reserve requirements. 

In contrast, PNM is a new participant in WRAP, a first-of-its-kind reliability effort started by the Northwest Power Pool, which changed its name to the Western Power Pool in February 2022 to reflect its expanding reach across the West.

“One of the things that makes the WRAP so beneficial is the ability to share in the diversity of the entire Western region,” Western Power Pool CEO Sarah Edmonds said in a news release. “Bringing in PNM adds to that diversity, in terms of geography, resource mix and seasonal loads.”

PNM’s generation fleet includes solar, wind, natural gas and coal resources. It has said it will meet the state’s clean energy mandate five years before the compliance date. The mandate requires utilities to have a zero-carbon power supply by 2045.

The company serves its 525,000 customers in Albuquerque, Santa Fe and 19 smaller cities, villages and tribal communities with 55% carbon-free energy.

It has participated in CAISO’s Western Energy Imbalance Market since April 2021, allowing it to buy and sell energy in the interstate real-time market.    

“We continue to ensure our customer needs are met through innovative solutions to our power resources, participation in energy markets and strengthening our resource adequacy framework,” PNM CEO Pat Vincent-Collawn said in a statement. “We see WRAP as another tool to continue to enhance PNM’s system reliability.”

WPP has been developing WRAP since 2020, initially to address concerns that Pacific Northwest utilities had been unknowingly drawing on the same shrinking pool of reliability resources. Interest in the effort quickly spread to other parts of the West; its footprint now covers all or part of 10 Western states and British Columbia.  

FERC approved WRAP’s tariff in February, saying the program “has the potential to enhance resource adequacy planning, provide for the benchmarking of resource adequacy standards and more effectively encourage the use of Western regional resource diversity compared to the status quo.” (See FERC Approves Western Resource Adequacy Program.)

The ruling allowed WRAP to move forward with a binding phase that will include penalties for members that fail to meet their resource-sufficiency obligations. WPP has the option to initiate the binding phase of the program during any season between 2025 and 2028, per the commission’s order. (See WPP CEO Looks to ‘Earliest Possible’ Binding Season for WRAP.)

The program involves two “time horizons” — a forward-showing program requiring participants to show they have sufficient capacity months in advance of summer and winter peaks, and an operational program, focused on the allocation of resources in the real-time and day-ahead time frames.

“PNM is expected to participate in WRAP’s forward showing later this year ahead of the summer 2024 operational program,” WPP said in its news release. “The forward showing component of the WRAP is where participants demonstrate they have secured their share of the region’s energy needs. The operational component, in the winter and summer seasons, is when utilities with a deficit can tap into the pool of shared resources if needed.”

WRAP participants in the Southwest include Arizona Public Service, Arizona’s Salt River Project and NV Energy.

Texas Legislature Moves Bills Remaking the ERCOT Market

Texas lawmakers have advanced several bills that, while revised, still threaten to upend the ERCOT market and punish renewable energy.

Introduced last month, the bills would fund the construction of 10 GW of gas-fired plants that would only be used to prevent load shed; place limits on how much renewable generation can be built; institute a firming requirement for all resources and load-serving entities; and mandate that generation be built closer to load to reduce transmission costs. (See Texas Senate Lays out Changes to ERCOT Market.)

The Texas Senate approved four bills Wednesday, three of which cleared the Business and Commerce (B&C) Committee earlier in the week. They include Senate Bill 6, which has drawn widespread opposition over its proposed Texas Energy Insurance Program. Under the program, interest-free loans from state funds — Texas has a $32.7 billion budget surplus — would be used to build break-glass-in-case “reliability assets,” defined as gas plants in ERCOT’s footprint with on-site fuel storage.

Charles Schwertner (Texas Senate) Content.jpgSen. Charles Schwertner, author of SB 6 and SB 7, explains his legislation to the Texas Senate. | Texas Senate

The bill’s detractors include Grover Norquist’s Americans for Tax Reform (ATR) conservative advocacy group. It said SB 6 and other legislation “all seek to impose arbitrary restrictions on energy producers or authorize superfluous subsidies.”

“While the motivation behind them is well-meaning, such misguided intervention is likely to produce barriers to entry that reduce competition and raise consumer prices,” the organization added.

SB 6 is similar to Berkshire Hathaway Energy’s proposal during the 2021 legislative session to fund $8.3 billion to build 10 GW of gas fired generation for “blackout insurance.” The proposal never made it into legislation. (See Stakeholder Soapbox: Berkshire’s Proposal Will Prevent Another Texas Power Catastrophe.)

The current legislation is expected to cost about $10 billion. However, the costs could be as high as $18 billion, according to a Lower Colorado River Authority document recently obtained through an open records request by Austin’s NPR radio station, KUT. In the document, LCRA says it could build about 5.6 GW of reliability assets for $10 billion in capital costs and about 10 GW for $18 billion.

State Sen. Nathan Johnson (D) reminded the B&C Committee Monday that stakeholders have raised concerns for several years over an off-market backup system that could have “damaging, perhaps destructive effects” to the ERCOT market.

Nathan Johnson (Texas Senate) Content.jpgSen. Nathan Johnson (right) questions the legislation. | Texas Senate

“To the extent we’re going to preserve our competitive market, I’m concerned that the scope of this is too large and it ought to be brought down considerably in size and work in conjunction with other elements,” he said. “It seems to wag the whole system at this size.”

“This bill … speaks to the concerns of millions of Texans regarding what do we do when there is anticipated extreme heat or extreme cold. Do we have enough backup electricity to make sure our grid doesn’t go down?” B&C Chair Charles Schwertner (R) said during Monday’s committee meeting. “This is just like a generator at your house. It is an insurance electricity backup system that stands behind the energy-only market here in Texas.”

Schwertner, who drafted the bill, said he had added several revisions after further input from 20 “major stakeholders” and hours of discussion with members and stakeholders. The modifications include weakening the thresholds project developers must meet to establish “financial stability” by reducing the applicant’s ownership of existing capacity from 15 GW down to 2.5 GW and not requiring total assets of $10 billion for every GW of capacity applied for.

However, applicants will be required to have an investment grade credit rating.

The substitute bill’s biggest revision keeps the program’s plants from entering the competitive day-ahead and real-time markets for 40 years and clarifies that Texas regulators should continue to work on market design fixes that address the state’s reliability issues.

That could satisfy some market participants who have said the temptation would be too great not to use the plants sitting on the sidelines.

“The concern is that you’re going to be paying for these resources and they’re going to be sitting there,” South Texas Electric Cooperative General Manager Clif Lange said during a legislative hearing last week. “It’s going to be extremely tempting when we come back in two years or four years to want to make sure that the [Public Utility] Commission uses these a little bit more frequently. I think you’re going to get pressured to try to make sure that those are deployed at a lower price level.”

Lange said that should the gas units enter the ERCOT markets, they could start displacing competitive resources and lead to price distortions.

“You start to see more pressure on the existing portfolio of assets and as a result, you potentially start flushing out more dispatchable generation,” he said, warning that lower-cost renewable generation will continue to replace inefficient thermal resources.

Energy producer WattBridge has spent $2 billion in adding 4 GW of fast-start gas generators since 2018. In testimony before both legislative bodies, CEO Mike Alvarado said his company is one of those that would be affected.

“The market we invested in over the last 36 months is not the market that exists today,” he said. “We do not anticipate investing any further in ERCOT; the current market conditions simply do not allow it, and the current legislation considered by the Senate makes it that much more challenging for our business.”

Other provisions in the substitute bill would cap the sidelined gas plants’ regulated rate of return at 10%. Independent research firm Clearview Energy Partners said the revised legislation would also ensure that a generator with one or more participating plants does not receive more than $100 million a year in revenue per gigawatt of installed generation capacity.

Should the state not provide sufficient funding for the program, the bill directs the PUC to set a nonbypassable charge to all transmission and distribution utilities, municipally owned utilities and electric cooperatives in ERCOT.

The Senate, controlled 19-11 by Republicans, passed SB 6 by a 22-9 margin, with one Republican and four Democrats crossing the aisle. Johnson and the other two Democrats on the B&C Committee all voted “present” Monday in sending the bill to the floor.

Another ‘Legislative Priority’

Senators also unanimously approved SB 7 Wednesday. Along with SB 6, it has been designated a “legislative priority” by Lt. Gov. Dan Patrick, who controls the Senate.

The bill creates a new “firming” ancillary services program that directs load-serving entities to purchase “dispatchable” reliability reserve services on a day-ahead basis. Revisions to the bill mandate that resources offering the service be capable of running for at least 10 hours, up from four hours as originally drafted. That would essentially lock out energy storage, which ERCOT considers dispatchable.

Americans for Tax Reform said SB 7 would subsidize energy capacity instead of compensating firms for electricity they sell and would create an “adverse incentive structure wherein energy producers would become more reliant on taxpayer subsidies.”

“This would hamper the Texas energy industry and likely lead to increased prices on consumers as well as producers,” Americans for Tax Reform said.

In testimony before lawmakers last month, ERCOT CEO Pablo Vegas called the concept a “tax” and said it could lead to increased generation retirements.

“We would lose energy resources in the short term,” he said. “Resources that cannot be economic under the new cost burden that’s put in place [by SB 7] would pull out of the market, so we would have an energy deficit from that.”

The Senate has already sent several other bills to the House of Representatives. They include:

  • SB 2012, which would establish policy guardrails should the PUC implement the performance credit mechanism. Lawmakers have thrown cold water on the construct, advising the regulators that they can’t go forward with it without legislative input.
  • SB 2014, which would make renewable energy credits voluntary instead of mandatory.
  • SB 2015, which would mandate that 50% of generating capacity installed in ERCOT after this year be sourced from dispatchable resources.
  • SB 1287, which would require developers to pay for some of the interconnection transmission costs, adding more hurdles for renewable resources that are built far from the grid.

Renewable generation already accounts for a bit more than half of ERCOT’s capacity and for most of the projects in ERCOT’s interconnection queue. According to a study by Joshua Rhodes, a University of Texas researcher, wind and solar resources saved Texas consumers $11 billion in just 2022.

“I worry that some of the bills come across as anti-renewable,” Sen. Judith Zaffirini (D) said Monday. “And so, we want to make sure that we have the dispatchable energy that we have but not necessarily hurt, not punish, renewables.”

EPA Proposes Tougher MATS Regs on Coal Power Plants

EPA last week took the next step in its campaign to clean up coal-fired power plants, proposing to strengthen the Mercury and Air Toxics Standards (MATS).

The changes would impose stricter limits on emissions of mercury and other metals, fine particulate matter, sulfur dioxide, nitrogen oxides and carbon dioxide.

EPA said in a news release Wednesday that the proposal would reduce by 67% the emissions of filterable particulate matter (fPM) from existing coal-fired plants. The proposal contemplates even lower emission limits for fPM and seeks comment on whether EPA should finalize a more stringent standard.

It would also require operators to run continuous fPM emission-monitoring systems; EPA estimates about two-thirds of existing coal-fired units do not currently use such a system. It also seeks to revise requirements to assure better emissions performance during plant start-up.

Finally, the proposed changes would bring plants that burn the lowest-grade coal, lignite, up to the same standards as other coal-fired plants. A fact sheet indicates lignite plant emissions limits would be slashed by 70%.

When issued in 2012, MATS required significant reductions of mercury, acid gases and other harmful pollutants from coal- and oil-fired power generation, framing them as a health threat. EPA called the proposal the most significant update to MATS in the 13 years since.

The agency had undermined the legal basis for MATS during the Trump administration but promptly moved to restore it after President Biden took office in January 2021. In February, EPA reaffirmed the scientific, economic and legal underpinnings of the regulations. (See EPA Reaffirms Power Plant Mercury Regulations.)

That move had little immediate impact, as U.S. coal plants were already in compliance, having reduced their mercury emissions by 90%. But it set the stage for further regulatory steps to limit the impact of a fossil fuel long blamed for pollution and climate change. EPA estimates its proposal would result in about 500 MW of coal-fired capacity retirement by 2028 but cause only minimal increases in the cost of electricity and natural gas.

After EPA reaffirmed MATS in February, it announced two other moves to limit emissions. In early March, it proposed tighter rules on wastewater emissions from coal plants. The Effluent Limitations Guidelines and Standards have followed a trajectory similar to the path of MATS: They were instated under President Barack Obama, weakened under President Donald Trump, then reinstated and expanded under Biden. (See EPA Proposes Tighter Coal Plant Wastewater Regs.)

In mid-March, EPA announced final details of its Good Neighbor Plan to slash emissions of smog-forming nitrogen oxides from power plants and industrial facilities in 23 states that contribute to ozone formation in downwind states. (See EPA Good Neighbor Plan Expected to Accelerate Coal Plant Retirements.)

Collectively, the changes and proposals may hasten the trend away from coal as a source of fuel for power generation in the U.S.; EPA’s wastewater proposal, for example, offers smaller decreases in emissions limits at power plants whose operators agree to stop burning coal by 2028.

Advocates for public health and the environment have cheered the moves, while those connected to the coal industry have criticized them. Others worry that the policy of speeding the pace of fossil fuel generation retirements while simultaneously pushing to electrify large swaths of society could result in shortages of power.

The divide was on clear display Wednesday between leaders of the U.S. Senate Environment and Public Works Committee after the MATS proposal was announced.

“The Mercury and Air Toxics Standards continue to be a remarkable, cost-effective success in reducing mercury and other toxic air pollution,” Chair Tom Carper (D-Del.) said. “Thanks to MATS, children and families are breathing cleaner air, and there is less pollution in our nation’s waters. EPA’s proposed rule would build on the progress made to better protect communities. This science-based rule will ensure that power plants use modern pollution-control technology, which will help save lives and support a healthy economy.”

Ranking Member Shelley Moore Capito (R-W.Va.) blamed the original MATS for closure of many coal-fired plants. “The Biden administration continues to wage war on coal and affordable, reliable energy by issuing unnecessary regulations intended to drive down electricity production from our nation’s baseload power resources,” she said. “With one job-killing regulation after another, the EPA continues to threaten the livelihoods of those in West Virginia and other energy-producing communities across the country.”

The American Lung Association said it would advocate for the more stringent options EPA is considering beyond its initial proposal. “EPA’s statutory requirement is to protect individuals from the maximum exposure to hazardous air pollutants, and the Mercury and Air Toxics Standards must be strengthened so that they adequately protect health from power plant pollution. The American Lung Association will work during the public comment process to strengthen the final rule to maximize health protections from power plant toxic pollution.”

The Union of Concerned Scientists hailed the benefits of the original MATS and bemoaned delays to its rollout a decade ago. “For all the good that MATS has brought, we must also reckon with the fact that all these towering benefits could and should have happened sooner, and lives were harmed in the time between. EPA cannot repeat that same delay today. While MATS has driven enormous benefits to date, the fact remains that coal- and oil-fired power plants still release pollution that hurts people and the environment, and it is incumbent on EPA to act.”