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November 5, 2024

MISO Enviros Say Broader Tx Planning Necessary

NEW ORLEANS — Clean energy advocates and a transmission developer asked MISO’s Board of Directors last week for stronger transmission plans and a facility blueprint for MISO South.

Southern Renewable Energy Association’s Andy Kowalczyk said he shared multiple stakeholders’ concerns that the grid operator has waited too long to address long-term transmission needs in the South.

Noting Entergy joined MISO in 2013, he said, “I know that in transmission planning terms that seems like yesterday, but MISO South has yet to be fully connected with our neighbors to the north. Only a narrow path between the north and south exists, and there’s been no truly regional planning in the subregion compared to the north in the past decade.”

MISO plans to bring a second long-range transmission plan (LRTP) portfolio forward for the board’s consideration sometime next year. The recommendation will again be focused on MISO Midwest and could hit $30 billion, staff have said. (See MISO Says 2nd LRTP Portfolio Still in Flux.)

During the board’s System Planning Committee meeting March 21, Aubrey Johnson, vice president of system planning, said MISO’s second, middle-of-the-road, 20-year planning future indicates renewable energy and carbon reduction will increase by 2030. Past Future 2 iterations didn’t anticipate the transformation until 2040; it will influence the second leg of MISO’s LRTP.

Beth Soholt 2023-03-21 (RTO Insider LLC) FI.jpgCGA Executive Director Beth Soholt | © RTO Insider LLC

Clean Grid Alliance’s Beth Soholt said MISO’s futures refresh is “further evidence” that the transition is happening at a much faster pace than anticipated.

“A trend we’ve always had with the utilities and at MISO is that transmission capacity is full before it is constructed and goes into service,” she said. “Given the very large interconnection queue in MISO, which is responding to demand for new resources, we are seeing this same trend again.”

Soholt said the Midwest’s first planned LRTP lines are quickly being spoken for. She said the future’s update almost triples the footprint’s renewable energy resources that will require sizeable transmission additions. Soholt urged the board to ensure staff is planning to build the bulk transmission system “at the appropriate bigness.”

Kowalczyk said despite MISO’s “major successes” with its Midwest LRTP plan, “the planning paradigm needs to change for the South.” He said it “should be unacceptable” that the grid operator will wait four years before it considers Southern needs.

The New Orleans resident said he was “genuinely worried” that the southern grid will falter during future emergencies. Kowalczyk said solar projects in Arkansas and Louisiana need new transmission capacity to come online.

“We need MISO to commit to planning for the future MISO South, for the good of the entire footprint,” Kowalczyk said.

NextEra Energy’s Matt Pawlowski urged MISO to be more aggressive on transmission planning. He said early green hydrogen projects, other new load and several generation developers want to join the system. Pawlowski said the region risks losing out on renewable energy and economic development if it doesn’t get more planning intensive.  

“None of this happens without transmission. The more aggressive we are, the better off we are to accommodate these loads,” he said. “The message to you on transmission is: We need to be aggressive on scenarios; we need transmission now. We’re already behind.”

Pawlowski said he doubted staff’s projections to energize the first batch of LRTP projects by 2028 or 2030. He said in his experience, construction and permitting should take 10 to 15 years, not MISO’s more optimistic forecast.

“Emerging industries like green hydrogen and offshore wind are getting a lot of attention from the business community and there are serious efforts to take advantage of federal incentives, but without being able to reliably deliver gigawatts of clean energy, they will not flourish,” Kowalczyk warned.

MISO’s “other” project category in its annual Transmission Expansion Plans drew interest at MISO Board Week. They include transmission owners’ projects needed for load growth and to address existing facilities’ ages and conditions. Stakeholders have said at times that the category appears to be a catch-all and is difficult to understand.

“How much work is MISO really doing to understand this category? I’d like to understand MISO’s due diligence on this,” Director Nancy Lange said.

Laura Rauch, senior director of transmission planning, said “other” projects often are largely driven by localized reliability needs, as opposed to NERC and regionally defined standards that drive baseline reliability projects.

LG Energy Solution Quadruples Size of Ariz. Factory Plan

LG Energy Solution said Friday it would build a $5.5 billion factory in Arizona with an annual capacity of 43 GWh of vehicle and stationary batteries.

Construction of the Queen Creek facility is expected to start later this year. It is part of a rapid production buildout by the South Korean company, which has said it plans to expand its global production capacity by 300 GWh in 2023.

LGES is planning, building or operating manufacturing facilities in Michigan, Ohio, Tennessee and Ontario, either alone or in joint ventures with automakers GM, Honda and Stellantis.

The LGES announcement Friday came a year to the day after the company initially announced it would build a factory in Queen Creek, Ariz.

But the plan announced March 24, 2022, had a construction price tag and annual output only about one quarter as large as the revised plan. And in June 2022 — as inflation was soaring and the South Korean Won had reached a decade-plus low against the U.S. Dollar — LGES appeared to be hesitating on its construction. The company told Reuters it was reassessing its plans in Arizona.

The economic landscape changed radically in August 2022, when Congress passed the Inflation Reduction Act, which creates incentives for American consumers to buy electric vehicles with American-made components and incentives for manufacturers to build those components in the U.S.

In its announcement Friday, LGES cited the rising demand from EV manufacturers for domestically produced batteries.

“Our decision to invest in Arizona demonstrates our strategic initiative to continue expanding our global production network, which is already the largest in the world, to further advance our innovative and top-quality products in scale and with speed,” CEO Youngsoo Kwon said. “We believe it’s the right move at the right time in order to empower clean energy transition in the U.S.”

LGES called it the largest single investment ever for a standalone battery manufacturing facility in North America.

It will comprise two factories.

One will build cylindrical batteries for EVs, is targeted to begin production in 2025 and will have an output capacity of 27 GWh per year.

The other will build pouch-type lithium iron phosphate batteries for energy storage systems (ESS), begin production in 2026 and have a designed capacity of 16 GWh per year. LGES said it would be the first ESS-exclusive factory in the world.

LGES also has manufacturing facilities in China, Indonesia, Poland and South Korea. It said in the news release that expanding its presence in the U.S. would allow it to decrease logistics costs and improve partnerships with its customers in both the EV and ESS sectors.

Other companies have announced plans for battery factories north and west of Arizona.

EV manufacturer Tesla earlier this year said it would invest $3.6 billion in production facilities in Nevada, including a new battery factory and a heavy-duty truck factory. (See Tesla to Invest $3.6B in Nev. Truck, Battery Factories.)

And Statevolt is pursuing development of a 54-GWh battery plant in Southern California, near the lithium deposits in the Salton Sea area. (See 54 GWh EV Battery Plant Proposed for Lithium Valley.)

Overheard at NE Electricity Restructuring Roundtable: March 2023

BOSTON — A panel of experts made the argument for smarter rate design on Friday at Raab Associates’ New England Electricity Restructuring Roundtable.

Updating rates to send better price signals is the key to unlocking the power of demand, the panelists said.

It’s a process that’s “more art than science, or more behavioral than economics,” said Janet Gail Besser, the panel’s moderator.

The speakers focused on Massachusetts, where the roundtables are held.

“With last fall’s Department of Public Utilities order requiring the utilities in Massachusetts to develop advanced metering infrastructure implementation plans, it appears there will be new opportunities for innovative rate design that can encourage electrification and reduce carbon emissions,” said Besser, a former chair of the DPU.

Electricity rates have been changing in structure for decades, but there’s one consideration that’s upped the ante in recent years, said Sue Tierney, a senior adviser at Analysis Group.

“What’s different now is the urgency of evolving the electric system as part of the path to decarbonizing the economy,” Tierney said.

An effective change to rate design to help start boosting demand is time-of-use rates, the panel agreed.

“Time-varying rates is an essential tool,” Tierney said. “Having it as a default option provides two opportunities: for the customer to take charge and figure out what they want to do in terms of their own energy management; and it sets up the context for … retailers and aggregators to use those time-varying rates.”

In the last few years, five states have started implementing opt-out time-of-use rates. Massachusetts is not one of them, and again the panel picked on the Bay State.

“Our customers in Massachusetts, we don’t know how much energy they’re using until we get the bill from utilities a month later. And we have no idea at any point in time when our customers are using energy,” said Travis Kavulla, vice president for regulatory affairs at NRG Energy. “So there’s no incentive or practical ability at all … for us to make investments in demand response.”

Melissa Whited, a senior principal at Synapse Energy Economics, offered another way to tweak rates to incentivize electrification of vehicles or home heating: playing around with how customers are charged.

For example, she said, states have traditionally tried to keep fixed charges low, and let volumetric rates stay higher, to incentivize customers to conserve energy.

“But with electrification, high volumetric rates are a barrier to adopting new technologies,” Whited said. So, California has experimented with high fixed charges with low volumetric rates limited to customers who are using certain demand-side technology.

There’s also an argument to be made for a broader overhaul, said Harvey Michaels, a lecturer at the Massachusetts Institute of Technology who has studied heat pump adoption.

“We have to realize as part of what we’re doing now that charging electric bills for the energy efficiency programs and other things we do, particularly when they’re competing with a gas-fired alternative, is shooting us in the foot,” Michaels said. “We have to figure out how to pay for these things with something other than electricity.”

Regulators Slash NV Energy’s Transportation Electrification Plan

Nevada regulators on Thursday gutted NV Energy’s proposed $348 million transportation electrification plan, slashing the budget to about $70 million and removing most of its proposed programs.

The whittled-down plan, which the Public Utilities Commission of Nevada (PUCN) voted 3-0 to approve, has three programs. They include an interstate corridor EV charging program, an electric school bus vehicle-to-grid trial, and an innovation demonstration program that will provide matching funds for federal Inflation Reduction Act grants.

The proposed plan encompassed 10 personal and six commercial vehicle programs. Programs that the commission axed include a $5,000 EV purchase rebate for low-income residents, incentives for home charger installations, EV charging infrastructure programs for multifamily housing and workplaces, and transit electrification grants. (See NV Energy Seeking $348M for Transportation Electrification.)

Commissioners said the plan as proposed was too broad and that financial analysis, including impact on rates, was insufficient.

Another concern was what commissioners called a lack of progress on a previous NV Energy plan, the $100 million Economic Recovery Transportation Electrification Plan (ERTEP) that PUCN approved in late 2021. The three-year plan, which runs through 2024, aims to bring about 1,822 EV chargers to 120 sites throughout Nevada. (See NV Energy Gets Green Light for $100M EV Charger Plan.)

“The most recent update showed there was no progress made in actual implementation of the [ERTEP] programs,” Commissioner C.J. Manthe said on Thursday. “At the end of 12 months, there was only program administration costs that were expended.”

Commission Chair Hayley Williamson also noted NV Energy’s lack of spending thus far on the ERTEP programs. Still, she said, the transportation electrification plan that the commission approved on Thursday is significant.

“Despite some of these programs being deferred or rejected, this is still an approximately $70 million budget for transportation electrification, which is clearly important to the commission,” she said.

NV Energy was required to file ERTEP and the more recent transportation electrification (TE) plan by Senate Bill 448, passed during Nevada’s 2021 legislative session. The company filed the TE plan as part of the third amendment to its 2021 integrated resource plan. The TE plan covers 2023 and 2024; an updated plan will guide transportation electrification programs after that.

NV Energy Response

In a statement provided to NetZero Insider after the PUCN vote, NV Energy said, “We are currently evaluating the details of the commission’s order.”

But in a Feb. 24 filing, NV Energy responded to criticisms that have been raised since the TE plan was filed in September.

The TE plan is complementary to the charging-station-focused ERTEP, the company said, bringing transportation electrification programs to most of its customer classes. With its broad scope, the plan is intended to fulfill the intention of SB 448, NV Energy said.

“To be clear, the direction from the legislature was not just to prepare for future electric vehicle adoption or to keep up with resulting load — it was to accelerate transportation electrification in this state,” the company said in its filing.

NV Energy said it provided information related to its TE plan “well in excess of” the requirements of SB 448. And regarding progress on ERTEP, the company said it is not behind schedule.

“ERTEP is in year one of a three-year plan,” NV Energy said.

Clean transportation advocates said Thursday that the PUCN decision leaves “gaping holes” in the state’s EV policies. They said support is particularly needed for residential and commercial customers who want to install EV chargers at their homes or businesses.

“Leaving out residences, particularly multi-family homes, is a huge, missed opportunity,” Joe Halso, staff attorney with the Sierra Club, said in a statement. “What has been approved today is far from the holistic support necessary to meet EV drivers’ needs and improve access to clean transportation options for all Nevadans.” 

Program Details

The TE plan’s interstate corridor charging depot program is an expansion of a program contained in ERTEP. Charging sites would feature two Level 2 chargers, six DC fast-charging ports and shade canopies, although NV Energy said site hosts could request fewer chargers.

NV Energy will offer site hosts an incentive for each charging port, with higher amounts for sites in disadvantaged communities. With a $23 million budget, the program is expected to support 10 charging sites with 80 charging ports.

The electric school bus vehicle-to-grid trial is also an extension of an ERTEP program. NV Energy is looking for about nine school district sites — two large and seven small — to participate in the trial, in which energy will be discharged from electric buses during peak periods. Priority will be given to rural school districts.

The $32 million program is expected to support about 110 charging ports at nine sites.

PUCN also approved $1 million that NV Energy can use as matching funds if it secures federal grants under the Inflation Reduction Act.

CAISO Board Approves Summer Readiness Measures

CAISO’s Board of Governors on Thursday approved measures to help ensure summer reliability, including extending for a third year a requirement that utility-scale storage batteries maintain a minimum state of charge during critical conditions.

The requirement “applies during very limited circumstances where we experience the most constrained conditions on the system,” such as during an extreme heat wave last September that brought CAISO to the brink of ordering rolling blackouts, said Anna McKenna, the ISO’s vice president of market policy and performance. (See California Runs on Fumes but Avoids Blackouts.)

In a memo to the board, McKenna and other CAISO staff members said the storage constraint “mitigates the risk storage resources may be unable to meet day-ahead discharge schedules in the real-time market because they were either insufficiently charged or discharged prematurely, leaving them unable to meet their day-ahead schedules for later hours when their energy may be essential to maintain reliability.”

The requirement was intended to be temporary when it was adopted in April 2021, following the rolling blackouts of August 2020. CAISO decided to extend it despite opposition from some stakeholders, primarily storage operators who said it puts them at a disadvantage when demand and prices are highest.

The ISO intends to replace the minimum state of charge constraint with a “more comprehensive set of tools” that the Board of Governors approved in December, but the software for its planned system upgrade is not yet ready, the staff memo said.

“These more comprehensive sets of tools, when implemented, will provide ISO operators with enhanced state of charge visibility and control via exceptional dispatch functionality,” it said. “These enhancements also provide opportunity cost compensation for resources that are exceptionally dispatched to hold state of charge.”

CAISO management had originally proposed extending the minimum state of charge requirement through September 2024 to allow for unanticipated delays in software development. But it pulled back on that plan because of stakeholder concerns and set Sept. 30, 2023, as the sunset date to ensure it “expires even in the event of implementation delays,” the memo said.

Capacity Procurement Mechanism

The Board of Governors also approved updates to the ISO’s capacity procurement mechanism (CPM) that it uses to purchase electricity to head off shortfalls during “significant events” such as summer heat waves. 

The changes are “limited but necessary for us to access capacity over the summer that may be needed to backstop should we be not sufficient with the resource adequacy capacity that we have,” McKenna told the board Thursday. 

CAISO ran into problems using its “backstop” CPM to find and procure capacity during summer heat waves in 2020 and 2021, partly because of its own rules, a staff memo said.

To fix those issues, CAISO management proposed four operational improvements, including two changes to its rules to help the ISO buy electricity that is “not contracted for during a significant event,” a staff memo said.

One change would let the ISO adjust the volume in megawatts of CPM resources “if the designated capacity already is committed and shown to the ISO as resource adequacy capacity.”

Another gives resource scheduling coordinators flexibility to designate resources for a significant-event CPM for less than 30 days, which has been the minimum term.

“Because of this rule, a resource scheduling coordinator may have to reject a mid-month significant event CPM designation because the designated capacity has an existing commitment or is unavailable for the following month,” the memo said. “This existing minimum term rule has prevented the ISO from accessing immediately needed and immediately available capacity.”

ERCOT Technical Advisory Committee Briefs: March 21, 2023

ERCOT stakeholders this week arranged a pair of workshops as they continue to work with staff to provide bridging alternatives for a market redesign intended to preserve and attract thermal generation.

The Technical Advisory Committee scheduled workshops for March 31 and April 10 to further define market changes that could be made until a final construct is in place. ERCOT staff plans to share a strawman for the meetings and present a final recommendation during the second meeting.

Staff then plans to present their recommendation to the ISO’s Board of Directors on April 18. If approved, the recommendation would then be handed over to the Public Utility Commission.

Bridge option feedback (ERCOT) Content.jpgSummary of feedback to ERCOT on the bridge option. | ERCOT

The PUC in January recommended to state lawmakers that ERCOT adopt a performance credit mechanism (PCM) as a reliability addition to the ISO’s energy-only market, intended to address resource adequacy and operational flexibility challenges. The PCM would retroactively issue incentive payments to dispatchable — and primarily thermal — generation that meets performance criteria during the tightest grid periods.

The legislature has pushed back on the PCM and filed a package of bills that include building 10 GW of gas-fired generation to sit on the sidelines until load shed is imminent. (See Texas Senate Lays out Changes to ERCOT Market.)

At the PUC’s direction, ERCOT staff has been soliciting input from stakeholders on a bridging mechanism until the final market design is developed. The options include a manually settled PCM, procuring more ancillary services, tweaking the operating reserve demand curve, and a backstop reliability service, previously offered by the PUC, to set aside capacity that is only dispatched during scarcity conditions.

Kenan Ogelman (ERCOT) Content.jpgKenan Ögelman, ERCOT | ERCOT

By early this week, stakeholders had filed more than two dozen comments on bridging options, providing feedback and alternatives.

“At this point, I couldn’t tell you what our recommendations are going to be,” ERCOT’s Kenan Ögelman, vice president of commercial operations, told TAC during its meeting Tuesday. “We’re still kind of working through the comments and finalizing our position. You should know what we’re thinking by [April 10].”

Ögelman said staff’s summary of comments received so far indicate “some kind of a convergence” around changes to the operating reserve demand curve (ORDC) and an “indicative PCM value.”

“But the indicative PCM value on its own would not be a bridge solution, so we’re weighing that,” he said.

Credit Group’s Charter Approved

TAC approved a charter for its new Credit and Finance Sub Group (CFSG) that will replace the Credit Working Group (CWG). The new stakeholder group will be comprised of credit professionals responsible for ensuring that appropriate procedures are implemented to mitigate credit risk in ERCOT in a “fair and equitable” manner.

Austin Energy’s Brenden Sager, serving as the CFSG’s temporary chair, said the CWG’s original charter was used as a starting point. It will review ERCOT’s protocols on creditworthiness requirements or collateral calculations and provide recommendations to TAC. The group has yet to solicit members.

The CWG had reported to the board’s Finance and Audit Committee since 2004, but directors last year asked that they be briefed by ERCOT staff on market credit issues. TAC agreed to take on credit oversight responsibilities and consolidated the group with its Wholesale Market Subcommittee’s Market Credit Working Group. The latter group will be disbanded. (See “TAC Shares Changes with R&M,” ERCOT Board of Directors Briefs: Oct. 18, 2022.)

Aligning ISO with Infrastructure Protection Law

TAC’s combination ballot, approved by members 30-0, brings ERCOT into compliance with the state’s Lone Star Infrastructure Protection Act (LSIPA). The 2021 law prohibits businesses and government entities from entering into agreements that would grant direct or remote access to critical infrastructure, such as the Texas grid, with foreign companies from China, Iran, North Korea and Russia.

The ballot included a nodal protocol revision request (NPRR1155) that would amend a market participant’s eligibility criteria and make any entity that meets any of the LSIPA’s prohibited citizenship, ownership or headquarters criteria ineligible to register or maintain its market participant registration.

The combo ballot also included two other NPRRs, another binding document request (OBDRR) and a Load Profiling Guide revision (LPGRR). It additionally contains a second LPGRR, a revision to the Nodal Operating Guide (NOGRR) and related single changes to the commercial operations (COPMGRR), planning (PGRR), retail market (RMGRR) and settlement metering (SMOGRR) guides, resource registration glossary (RRGRR) and verifiable cost manual (VCMRR).

The ballot includes:

  • NPRR1145: change the 15-minute level ERCOT-wide transmission loss factors (TLFs) in the settlement process from seasonal base case TLFs to state estimator-calculated TLFs in the energy management system and clarify non-opt-in entities’ deemed actual TLFs to remove behind-the-meter transmission losses.
  • NPRR1157: require all revision requests be approved by the PUC before their implementation; add a credit review, Independent Market Monitor and ERCOT opinions, and the market impact statement to the board’s TAC report; and revise possible actions on RRs from “defer” to “table,” as currently captured in motions.
  • COPMGRR049, LPGRR072, NOGRR248, PGRR104, RRGRR034, SMOGRR026 and VCMRR036: require all RRs be approved by the PUC before implementation; standardize all RRs considered by the ERCOT board; add IMM and ERCOT opinions, and the market impact statement to the TAC Report; and revise possible actions on RRs from “defer” to “table,” as currently captured in motions.
  • LPGRR071: halve the required lead time from 120 to 60 days for an opt-in entity to provide ERCOT the monthly usage and demand values for its electric service identifiers (ESI IDs).
  • OBDRR044: eliminate the weatherization-inspection fee’s sunset date and change its invoicing period from a quarterly to a semiannual basis.
  • RMGRR173: requires all RRs be approved by the PUC before their implementation; standardize all RRs to be considered by the ERCOT board; add a credit review, IMM and ERCOT opinions, and the market impact statement to the board’s TAC report; and revises possible actions on RRs from “defer” to “table,” as currently captured in motions.

Sierra Club Sues Largest Ill. Coal Plant over Permitting

One of the largest power plants in Illinois has been running without proper permits since it went into service, the Sierra Club contends in a lawsuit filed Thursday.

As a major source of emissions, the Prairie State Energy Campus needs a Title V permit under the federal Clean Air Act, the environmental advocacy organization said, but has held only a Prevention of Significant Deterioration (PSD) permit since it went online in 2012.

The operator, Prairie State Generating Company, countered that the 1,600-MW plant is operating legally with the PSD issued by state regulators and called the Sierra Club’s lawsuit a politically motivated attempt to sidestep state regulations.

Under Illinois’ landmark 2021 Climate and Equitable Jobs Act, privately owned coal-fired power plants must shut down by 2030 but publicly owned plants such as Prairie State can run until 2045.

Megan Wachspress, the Sierra Club staff attorney who filed the lawsuit, said the action seeks a declaration that the plant cannot operate without a Title V permit.

Permit History

The Prairie State Energy Campus in Marissa, in southern Illinois, is owned by nine public power utilities and rural electric cooperatives. Coal mined on site is pulverized to powder and burned to run two 800-MW units that send electricity to customers in eight states.

It boasts of setting a new standard for clean coal production and of investing $1 billion in emissions controls.

The U.S. EPA’s ECHO database lists 2021 emissions of 8.2 million pounds of nitrogen oxides and 21.1 million pounds of sulfur dioxide. Both substances are potentially damaging to human health and the environment.

By state and federal statute, Wachspress said, these numbers make the facility a major source of pollutants and require it to hold a Title V Permit.

The Sierra Club’s lawsuit indicates Prairie State applied for such a permit — which is called a Clean Air Act Permit Program (CAAPP) in Illinois — in January 2010, updated the application in May 2011, and applied again in July 2020.

Neither of those applications was approved, Sierra Club writes.

Illinois regulators did issue a Construction Permit/PSD approval to Prairie State on March 30, 2012, Sierra Club said, but that’s not enough because the plant is a major emitter, and under state law Illinois’ failure to act on the CAAPP application constitutes a constructive denial.

Asked by NetZero Insider about the legality of Prairie State operating for a decade with a PSD, the EPA’s district office deferred to the Illinois Environmental Protection Agency, which declined comment.

Enforcement Sought

Wachspress could only speculate on how this went on for so long.

“This is such a fundamental requirement you just assume it’s being done,” she told NetZero Insider Thursday. “It’s disappointing that the Illinois EPA didn’t act on it.”

She said Prairie State has been on the Sierra Club’s radar for a while because of its huge output of harmful substances. The U.S. EPA’s Greenhouse Gas Reporting Program shows it to be by far the largest single source of CO2 emissions in Illinois in 2021, at 12.5 MMT.

There have also been a series of violations cited by the state and federal EPAs, Wachspress said.

After Prairie State was cited for exceeding federal limits on mercury emissions in 2021, Sierra Club began digging and discovered the lack of a CAAPP permit.

Sierra Club announced the lawsuit Wednesday. It was filed Thursday in U.S. District Court, southern Illinois.

Prairie State declined comment on the legal action itself but commented at length on the allegations at its root.

Vice President Alyssa Harre said via email that Prairie State “is operating legally under a Prevention of Significant Deterioration permit from the Illinois Environmental Protection Agency. To comply with this permit, Prairie State installed and has maintained more than $1 billion in state-of-the-art emissions control technology and continuous emissions monitoring system.

“This action by the Sierra Club’s California-based Environmental Law Program is a politically motivated attempt to circumvent the Illinois regulatory process, the consequences of which will bring instability to our electric grid to the detriment of the consumers we serve.

“Prairie State remains committed to working with the IEPA to maintain compliance with environmental regulations and will not let this lawsuit distract from our mission of providing value to the communities served through the continued production of reliable and affordable power, all while providing jobs and maintaining economic prosperity for hardworking men and women across downstate Illinois.”

The lawsuit is a citizen enforcement action, an attempt to force compliance with regulations that can be filed 60 days after the complainant gives notice of alleged violations to the parties involved.

Sierra Club said it gave such notice more than two months ago to EPA, IEPA and Prairie State.

Only Prairie State is named as a defendant in the lawsuit, which asks the court to:

  • declare that Prairie State is violating the Clean Air Act and Illinois air regulations;
  • enjoin Prairie State from operating the power plant until it obtains a CAAPP permit and is in compliance with the Clean Air Act;
  • impose of civil penalties, and designate $100,000 for mitigating public health and environmental projects;
  • order payment of Sierra Club’s legal costs.

NERC RSTC OKs Standards Projects, Reliability Guidelines

CLEARWATER BEACH, Fla. — As this week’s meeting of NERC’s Reliability and Security Technical Committee (RSTC) wrapped up in Florida, Vice Chair Rich Hydzik invoked the movie “Moneyball” to explain his committee’s place in the “data-driven world” of electric reliability.

“There’s a scene in that movie where [baseball manager] Billy Beane wants to draft somebody the scouts have never heard of, and they … have another pick they want. He says the numbers don’t back that up, and their answer is that he has the intangibles; you can’t measure the intangibles,” Hydzik said. “I think this meeting kind of highlights the intangibles that complement that data-driven approach to things we do.”

This week’s two-day meeting is the only fully in-person gathering planned for the committee this year. (See “Future Meetings,” NERC RSTC Briefs: Dec. 6-7, 2022.) For the June meeting at the MRO offices and the September meeting at WECC’s office, leadership intends for only members to attend in person while observers participate online. The final meeting of the year in December will be entirely virtual.

Standards Projects Move Forward Despite Data Concerns

NERC’s System Planning Impacts from Distributed Energy Resources Working Group (SPIDERWG) brought two Standard Authorization Requests (SARs) to the committee for endorsement, one of two standards actions the committee took this week.

The SARs are intended to modify existing reliability standards FAC-001-4 (Facility interconnection requirements) and FAC-002-4 (Facility interconnection studies) to require more consideration of potential reliability impacts from distributed energy resources (DER) before they are integrated to the electric grid. (See p. 129+ of agenda for SARs.)

This was the SARs’ second time before the RSTC; SPIDERWG Chair Shayan Rizvi brought them to the committee in December as well, though at that point the group was only seeking comment from committee members.

At Wednesday’s session, Nate Schweighart of the Tennessee Valley Authority expressed concern that the SAR was “getting a little bit ahead of the data,” citing the lack of centralized information sources on DERs, and of agreed-upon channels for accessing the information.

“You guys are putting requirements on the DPs [distribution providers] to provide the data, but there’s a large number of DPs; how we coordinate the information between the DPs to aggregate the DER information in order to properly study it, I think that all has to be figured out,” Schweighart said. “And then to require those things to happen before we have the data, I think, will cause some chaos amongst the transmission planners to figure out how to do it.”

Stephen Crutchfield Rich Hydzik Greg Ford 2023-03-22 (RTO Insider LLC) Alt FI.jpgFrom left: RSTC Secretary Stephen Crutchfield, Vice Chair Rich Hydzik, Chair Greg Ford | © RTO Insider LLC

John Moura, NERC’s director of reliability assessment and performance analysis, pointed out that “there’s a lot of things we have to study that we don’t have the data for.” He suggested that the presence of a mandatory standard could provide an impetus for DPs and other stakeholders to build the communication infrastructure needed to share the information efficiently.

David Grubbs from the municipal electric utility in Garland, Texas — who described himself as representing “both the DPs and the TPs [transmission planners] in our organization” — supported the SARs, saying the measures are “probably several years overdue.”

However, he also warned that he didn’t “think the data exists right now.” He suggested that the standard drafting team (SDT) to which the SARs are eventually assigned be encouraged to give utilities “a year or two” to collect the data.

“It’s going to take a while for the DPs to get data that is meaningful, and even after you get the data to put it in the model, and [make] sure the model solves and … do some testing to make sure that represents the real world,” Grubbs said. “So, I agree it needs to be done, I just think that … in our implementation plan, [we need to] make sure that we give adequate time to get verifiable data out of the distribution providers.”

Calling for a vote on the SARs, Chair Greg Ford said the issue came down to “timing of data versus studies,” and said he was confident the committee could work with the SDT and others involved in the process “to make sure that timing is there.” Members voted unanimously to endorse the SARs; they will now move to the Standards Committee, which will decide whether to approve them and assign a SAR drafting team.

Also before the committee this week was a SAR to modify MOD-031-3 (Demand and energy data). The measure, which was also brought by the SPIDERWG, would allow planning coordinators (PC) to “obtain existing and forecasted DER information from DPs or TPs” to ensure that the data “is available to the parties that perform reliability studies and assessments.”

Unlike the earlier SARs, SPIDERWG was only seeking reviewers from the RSTC, so no vote was needed. Secretary Stephen Crutchfield promised to email the draft SAR to the committee so that any interested members could volunteer.

Guidelines Approved

The RSTC also approved several reliability guidelines at this week’s meeting. Although these are not binding, their adoption is “highly encouraged” by NERC.

The first guideline, “Electromagnetic Transient [EMT] Modeling for BPS-Connected Inverter-Based Resources,” was submitted by the Inverter-based Resources Performance Subcommittee (IRPS). Designed as a reference for TPs and PCs that are performing EMT studies during the interconnection study process, the guideline is intended to “serve as a foundation for future EMT modeling related activities of IRPS.”

Next was a guideline intended to inform utilities on the Institute of Electrical and Electronics Engineers’ (IEEE) Standard 1547-2018, which relates to the interconnection and operation of DER. Although the IEEE standard only involves resources that are connected to the distribution system — and therefore not subject to NERC jurisdiction — SPIDERWG felt a guideline was needed because the installation and use of DERs “require coordination between distribution and transmission entities.”

The Supply Chain Working Group brought to the RSTC a guideline on avoiding cyber supply chain security risks, while the Real Time Operating Subcommittee (RTOS) submitted guidelines on addressing cyber intrusions and on gas and electric industry coordination.

EPSA Panel Debates How to Minimize Consumer Pushback as Bills Climb

WASHINGTON — Panelists at the Electric Power Supply Association’s (EPSA) Competitive Power Summit on Tuesday warned that the clean energy transition could be slowed or side-tracked by consumers if their monthly energy bills continue to rise.

“We’re at a crossroads where costs are going nowhere but up,” said Christine Tezak, managing director at industry analysts ClearView Energy Partners. “And the question is, are we going to be able to make a value proposition so that the consumer feels they’re getting value for the increased cost?

“It’s going to be necessary to convince consumers that not only are they getting a lower-carbon alternative, but they’re getting increased reliability and better deliverability in that product,” Tezak said. “Because it’s not just about keeping … the body warm, but it’s not having my electricity bill be something that speaks to me every month in a negative way.”

From McKinsey to PJM to the International Energy Agency, estimates of the cost of the global energy transition, and the investments needed in the coming years, generally fall within a range of $1 trillion to $4 trillion annually through 2050. But the EPSA panelists had different view on how those figures might play out and what potential pathways to a reliable transition might look like.

Stacey Doré, chief strategy and sustainability officer for Vistra (NYSE:VST), sees maintaining and expanding competitive power markets as an effective way to keep costs down for consumers, arguing that utility bills in competitive markets are lower than in regulated markets. (See After a Quarter Century Industry Experts Still Split on Restructuring.)

“As a competitive retailer, a power generator, our shareholders are taking on a lot of risk [for] these higher costs as opposed to just passing them through to the ratepayer,” Doré said.

At the same time, Vistra’s investment strategy is centered on shareholder returns, she said. For example, with the acquisition of Energy Harbor, owner of four nuclear reactors in Ohio, Pennsylvania and West Virginia, Vistra now has the second largest portfolio of carbon-free dispatchable power in the country, according to a company press release. (See Vistra Pays more than $3 Billion for Energy Harbor.)

The company has committed to reducing its greenhouse gas emissions 60% below 2010 levels by 2030.

Representing Wall Street’s perspective, Anthony Crowdell, managing director at Mizuho Americas, an investment banking firm, said investors have gotten “very used to very attractive earnings growth rates” from regulated electric utilities, which receive guaranteed rates of return on their capital spending. Investors’ concerns now turn on the likelihood that inflation and higher electricity bills will trigger regulatory pushback ― limiting rates of return ― and whether “what utilities have promised in the past, they may not be able to deliver,” Crowdell said.

But most consumers don’t understand or care about competitive versus regulated markets or the skittishness of equity investors, said David Springe, executive director of the National Association of State Utility Consumer Advocates (NASUCA).

“They just know at the end of the day, the bills are going up,” Springe said. “It’s the same kilowatt-hours that were turning the lights on 20 years ago and turning the lights on 10 years ago and turning the lights on last week. It’s the same kilowatt-hour; it just costs 100% or 200% more than it used to. You’re not going to explain that to customers, and you will see political pushback. …

“The same people that just arbitrarily say we’re going to have 100% [electric vehicles] by 2035 are the same people that will arbitrarily tell utilities to stop raising rates,” he said.

Defining ‘Affordability’

Exactly how to balance the conflicting priorities of the transition has become an ongoing conversation within the energy industry and at conferences like the Competitive Power Summit. EPSA’s membership is predominately independent power producers who advocate for competitive wholesale power markets.

Climate advocates point to the mounting physical and financial impacts of extreme weather events, as well as the new federal subsidies for clean power in the Inflation Reduction Act as clear signs for acceleration. Releasing the U.N.’s 6th Assessment Report Synthesis on climate change on Monday, Secretary General António Guterres called for the largest industrialized nations of the world to phase out all coal-fired generation by 2030. (See Guterres: G20 Nations Should Commit to Net Zero by 2040.)

But industry insiders like Doré argue that reliability and cost should determine the pace of the transition. Wholesale power markets have a vital role to play, sending appropriate price signals to advance policy objectives while minimizing price increases for consumers, she said.

Pace is “the key to the transition,” Doré said. “Our markets need to send the right price signals to build the kind of generation that we need.”

The war in Ukraine, for example, has opened questions about the need for new gas-fired generation, Doré said. “We look all the time at whether it’s economic to build new gas plants. In most markets today, it’s not because the investment signals are not there.”

She called for “an honest conversation about what is the right pace. What is the all-of-the-above strategy [for] getting eventually to deep decarbonization? I think we have to talk about investment signals. We have to talk about demand response. We have to talk about all the different methods of getting there. But we also have to be realistic about what the goals are,” Doré said.

Springe countered that the focus on building big projects to push the transition forward could be counterproductive, given the long lead times and resulting high costs needed to permit and construct such installations.

“I worry that there’s sort of a focus on big and fancy, and where the money and incentives should be is local, close: demand response, energy efficiency, solar, batteries; things that are near, because we can build those. So, I worry that we’re going to lose speed, in a sense, chasing the big and really miss out on an opportunity to accomplish the small,” he said.

Another part of the problem is that few states or regulatory commissions have a legal or structural definition of “affordability,” Springe said. While not offering a definition of his own, he called for “a very specific process to define what [affordability] is, whether you have it in your statutes or you don’t,” he said. The process also needs to be part of project planning, Springe said, “not after they’ve built an asset and have come to bring it and integrate it” into a rate base.

“You’ve got to define a metric, and you’ve got to do it up front,” he said. “What is it? How do you enforce it? … And how many things can we actually build in the state in that affordability metric?”

How We Buy Electricity

Tezak took a more market-based approach to the issue of ordering priorities, noting first that the emerging technologies that will be needed for long-term decarbonization “require time to be demonstrated, for you have to have a couple of [projects] get online before anybody makes money.” A “real portfolio concept” for procuring capacity could incorporate “a lot of character attributes,” she said.

One way forward could be “rebundling some of the capacity for long-term procurement with [clean energy] development … and coming to grips with what that capacity is,” she said. “The capacity market doesn’t have to be limited to the auction. I think to build faith back into markets, we may have to step away from defining them solely as a terrifically functioning auction because it isn’t how you buy anything else, and it’s not how we’re buying energy for this transition,” Tezak said.

“We’re talking about [power purchase agreements]; … we’re talking about interconnection; we’re talking about all that stuff, and the perfect, well functioning auction that we had for a couple of years seems to exist in a parallel universe,” she said. “Is it time to take the plunge of talking about not doing tweaks but doing major changes and what that means? And that’s hard because investors don’t like uncertainty and many of them … really dislike change.”

But Doré doesn’t think the markets need fixing per se. “The problem is we’re not allowing the markets to function the way that they were designed to function,” she said. “Things like market caps or trying to adjust capacity accreditation in a way that disadvantages dispatchable generation are interferences in the market that are going to scare away investors. …

“The problem is we have so many changes in our markets every time the legislature meets or every time the commission meets or every time FERC or one of the ISOs meet. … That just injects a lot of uncertainty for investors,” she said. “So, the ground is always shaking beneath you a bit.”

Mizuho’s Crowdell agreed that investors are looking for stability in markets across a range of variables, such as cost recovery after extreme weather events. Should shareholders or consumers pay, and who decides? Securitizing costs after an extreme weather event could reduce impact on customers’ bills, but in the long term, the customers who end up paying 10 or 20 years down the road weren’t even around when the costs were incurred, he said.

“When you think about the regional market, their concerns are different that the actual individual state,” which could also be different from those of individual legislators or regulators, he said. And legislative turnover in states continues to accelerate.

“We’ve seen much quicker changes in the state house,” he said, with the projects and policies of one administration being rolled back by a new set of players. “The equity holders are trying to balance [to] see where it’s going.”

But the panel circled back to the core issue of whether consumers might reject any further rate increases for clean energy. While consumer advocates are often uncomfortable with such questions, Springe said, “we really need to have a much broader discussion around what the price is going to be and figuring out how to match that up with when assets or resources appear.”

The special rates some utilities have introduced that encourage charging EVs at specific times of the day are one example of the kinds of rate design that will be needed going forward, Springe said. Doré agreed, pointing to Vistra’s Free Nights and Solar Days pricing plan in Texas that “encourages customers to use energy at the time of day when there’s less burden on the system.”

“Those kinds of plans are not possible unless you have a robust, competitive retail market,” she said. “If you want customer innovation, you’ve got to have competition.”

Youngkin Signs Energy Bills to Aimed at Growing Southwest Virginia Industry

Virginia Gov. Glenn Youngkin (R) signed a half dozen bills on Thursday that he said will deliver on his “All-American, All-of-the-Above Energy Plan.”

“Today is a great day for Virginia energy and American energy,” Youngkin said. “With the bills I’m signing, we’re moving closer to delivering on the All-American, All-of-the-Above Energy Plan I put forward last year. We can, in fact, make Virginia energy more reliable, affordable and clean while creating jobs and spurring innovation, and today is a testament to that.”

Youngkin said the legislation will help make Southwest Virginia the energy capital of the commonwealth while unleashing potential for the entire state.

The bills include HB 2386, introduced by Del. Israel O’Quinn (R), that creates the Virginia Power Innovation Fund, intended to jumpstart the creation of energy technologies and start to set up a nuclear innovation hub in the state. Other technologies that it will fund include carbon capture and storage, hydrogen, and energy storage.

The governor also signed Quinn’s HB 1779, creating the Nuclear Energy Grant Fund that will award grants to the commonwealth’s colleges and schools for the creation of employment and training pathways in the nuclear power industry, including nuclear engineering and nuclear welding.

A third bill from Quinn also got signed by the governor: HB 1781, which empowers the Southwest Virginia Energy Research and Development Authority to promote projects on brownfield coal sites, develop the energy workforce in the region and advance southwest Virginia’s energy industry. The research and development authority is a panel that seeks to promote energy development in the region, consistent with Virginia’s Energy Plan.

Youngkin signed HB 1643, which was introduced by House Majority Leader Terry Kilgore (R), which holds that it is the policy of Virginia to use coal mine methane gas produced from an underground area associated with mined-out coal seams. It requires the Department of Energy to evaluate the resource’s potential and to come back with a report to Youngkin and legislators on its findings by Nov. 15.

“Having lived my whole life in Southwest Virginia, I know the promise that exists in our mountains and valleys,” Kilgore said. “Energy innovation brought good paying jobs, and my bill to support the capture and use of coal mine methane from former coal sites is another example of Southwest Virginia leading the way in energy innovation.”

Sen. Travis Hackworth’s (R) SB 1468 provides that funds in localities’ Coal and Gas Road Improvement Funds may go toward flood mitigation infrastructure in the southwest of the state. Current law allows localities to tax up to 1% of the revenue from coal and gas production for building out roads and new water and sewer infrastructure.

The final bill Youngkin signed came from Del. Will Moorefield (R). HB 2178 is meant to add more coal mine methane extraction to the jobs eligible to receive green and alternative energy job creation credits.