Page 322 – RTO Insider

March 14, 2023December 14, 2023

Texas PUC Order Clears LP&L’s Path to ERCOT, Retail Choice

Texas regulators last week approved a settlement that clears the way for Lubbock Power & Light to complete its migration from SPP to ERCOT and begin offering retail choice to its customers.

The Public Utility Commission on March 9 approved an agreement between the utility and Southwestern Public Service (SPS) over the termination of a power contract that was to end in 2044. As part of the settlement, LP&L agreed to pay $77.5 million for the contract’s early termination (53529).

Golden Spread Electric Cooperative threw a late wrench into the proceeding in December when it filed opposition to the allocation of the termination payment between transmission and production functions. The co-op, which is connected to the SPS system, said the commission did not need to approve the allocation to green light the utility’s integration into ERCOT and that the issue should be adjudicated by FERC instead.

“The allocation of that payment is kind of a poison pill on the rest of the agreement,” PUC Chair Peter Lake said, pointing to LP&L’s plans to give its customers access to retail choice.

Golden Spread counsel James Guy agreed that the settlement’s proposed allocation wasn’t necessary for LP&L’s move into ERCOT. After a sidebar discussion with the other parties, the cooperative agreed to drop its opposition at the PUC. However, it reserved the right to take up the issue at FERC.

“Given the timing constraints we have … it has really never been our intent to slow the move of a group of consumers that are willing to go to ERCOT,” Guy told the commission. “We don’t intend and promise to not collaterally attack the commission’s order or make any argument of a lack of evidence for the order or anything along those lines.”

“Welcome to ERCOT,” Commissioner Will McAdams told LP&L and Lubbock city representatives.

The settlement applies to a little more than 25% of LP&L’s load, or about 170 MW. The bulk of LP&L’s load, about 470 MW, was smoothly migrated from SPP to ERCOT in 2021, the largest single transfer of customers in the latter’s history. That culminated a six-year engineering and regulatory effort that began in 2015. (See Six Years in the Making: LP&L Migrates Load to ERCOT.)

Reliant Energy Retail Services, TXU Energy and Octopus Energy have agreed to serve as safety net providers for LP&L customers. The utility will then become a transmission and distribution utility.

$1.75M Fine Recommended for TNMP

The PUC’s enforcement staff has recommended an administrative penalty of $1.75 million for Texas-New Mexico Power Company (TNMP) over its violation of metering and billing practices.

In a report, the commission’s Division of Compliance and Enforcement said the utility violated accurate meter-reading rules because it failed to make necessary changes to its advanced metering system.

A staff investigation found the utility had three-years’ notice that the system’s communication backbone was going to be discontinued but did not make replacement plans until halfway through the timeframe. They also said TNMP could have developed a back-up mitigation plan in case its vendor was unable to provide more than 170,000 new meters in time to avoid the “foreseeable” communications failures.

The results were prolonged, inaccurate estimates of power consumption for thousands of the utility’s customers.

TNMP has until March 28 to either accept the penalty or request a hearing. The recommended penalty will go into effect without a timely response.

March 14, 2023

NYISO Begins 2023 Class Year with Nearly 100 Projects

NYISO on Tuesday formally announced that the 2023 Class Year (CY23) study was launched with between 80 and 90 projects participating.

Class Year studies assess whether a new resource entering the New York grid would have an impact on reliability and identifies any transmission upgrades necessary to maintain reliability. CY23 officially started on Feb. 13, 30 days after the completion of the CY21. (See “Class Year Updates,” NYISO TPAS Briefs: Jan. 19, 2023.)

The abundance of projects joining CY23 is emblematic of a problem concerning NYISO’s interconnection study processes, which have undergone an unprecedented increase in the volume and complexity of projects since the passage of New York’s aggressive clean energy transition roadmap, the Climate Leadership and Community Protection Act.

NYISO has responded to this challenge by narrowing certain study scopes, considering tariff revisions and adding more staff. (See NYISO Investigating Tariff Changes to Improve Interconnection Processes.)

However, previous delays and the increase in projects requesting interconnection did force some projects to obtain waivers from FERC granting them more time to have their studies approved before being able to participate in CY23. (See “FERC Interconnection Waivers,” NYISO Operating Committee Briefs: Feb. 13, 2023.)

In an episode last month of NYISO’s podcast, “Power Trends,” Zach Smith, vice president of system and resource planning, extolled the ISO’s interconnection process, saying the study’s “core objective is about the reliability of the grid” and ensuring new resources entering the grid will not “degrade the performance of system so that we can keep the lights on and keep the quality of service for all customers in New York.”

Smith acknowledged that NYISO’s studies have become more complex and challenging, both because of the volume of proposals and that many resources rely on new technologies, creating a backlog of nearly 500 projects.

NYISO “recognized that the interconnection process must continue to evolve,” saying in a white paper that the “influx of new projects in the interconnection queue means that additional reforms are needed.”

In an email to RTO Insider, Smith said, “We’re extremely pleased to have launched another Class Year study process.”

“We understand how important the process is to supporting state policy goals and keeping the electric system reliable through the grid in transition.”

March 14, 2023June 14, 2023

NJ Governor Names 2 New BPU Commissioners

New Jersey Gov. Phil Murphy (D) has nominated a member of his staff and an NRG Energy executive to replace two sitting commissioners on the state’s Board of Public Utilities as the agency implements his reshaping of the state’s energy sector.

Christine Guhl Sadovy, Murphy’s cabinet secretary who has a history of working in clean energy, will replace Murphy appointee Robert Gordon, whose term expires Mar. 15, 2023.

Commissioner Bob Gordon | NJ BPU

Marian Abdou, managing senior counsel at NRG Energy (NYSE:NRG), will replace Dianne Solomon, who was nominated by Republican Gov. Chris Christie in 2013 and whose term expires in October 2024. Abdou has also worked at Direct Energy and Hess Corp.

The nominations require approval by the state’s Senate Judiciary Committee, which has yet to set a date to consider them, and the full Senate.

The changes come as the BPU works to implement some of Murphy’s most high-profile policies, among them aggressive efforts to create a state offshore wind industry, reduce transportation emissions through a dramatic expansion of electric vehicle use, and transition buildings away from natural gas heating and hot water appliances and towards electrification. The BPU is also faced with engineering an upgrade to the state grid necessitated by increased amounts of variable renewable generation.

The governor’s office did not respond to a request for comment on why the two existing commissioners were not reappointed. Members of the five-member board of commissioners serve six-year terms, with a salary of $175,000 and cannot hold another job. No more than three commissioners with the same party affiliation can serve on the board.

Closing Coal Plants

Sadovy joined the Murphy administration at the BPU, where she rose to the position of chief of staff to President Joseph L. Fiordaliso, according to her biography on the state website. She helped “spearhead” Murphy’s clean energy agenda, working on the governor’s 2019 Master Plan, the implementation of the 2018 Clean Energy Act and the development of the state’s EV incentive plan, according to the website.

She previously had spent five years advocating for clean energy policies at the New Jersey branch of the Sierra Club, where she worked on the Beyond Coal campaign, which seeks to close all the coal-fired plants in the U.S. Subsequent to that, Guhl Sadovy was political director for Planned Parenthood Action Fund of New Jersey and worked to help the election of pro-women’s health candidates, according to the site.

Abdou joined NRG in 2016 and has worked on a variety of commercial issues affecting the company’s generation assets and provided legal support to both the development and energy services groups, according to Murphy’s office. The company generates electricity and provides energy solutions and natural gas to millions of customers, according to the company website. NRG operates 10 natural gas plants, a nuclear plant, a solar plant and four coal plants, according to the site.

Abdou received her law degree and a Master of Business Administration degree from Rutgers University; she has worked at Day Pitney, Thacher Proffitt & Wood and ArentFox Schiff.

Advancing Clean Energy

Gordon, a Democrat who served 10 years as a state senator, is known as a policy wonk who on appointment to the board immersed himself in the details of energy issues; he is also known as someone who spoke his mind on occasion.

In one of his most notable comments, Gordon expressed frustration at the size of the subsidies awarded to PSEG’s three South New Jersey nuclear plants, in April 2021, saying he had hoped the company would agree to an award that was smaller than the maximum allowed under the law. “That never happened,” Gordon said at the time, but he nevertheless voted for the award. (See NJ Nukes Awarded $300 Million in ZECs.)

Commissioner Dianne Solomon | NJ BPU

One environmental advocate said Gordon may have spoken too frankly at some point, prompting his removal.

Gordon said it had been “a great privilege to advance Governor Murphy’s groundbreaking policies in clean energy.

“I look forward to continuing to shape policy in my next chapter,” said Gordon, who is also a trustee on the board of New Jersey Transit, the state mass transit agency. “I remain very interested in clean energy and hope to continue my involvement in the field.”

Solomon, a Republican who is serving her second term on the BPU board, is a former BPU president and member of the governor’s cabinet under Christie. She has on occasion bucked the board, questioning the pace of the state’s push into clean energy. On Feb. 17, she voted against awarding an easement needed to advance the state’s first offshore wind project, saying she did not believe the board had investigated the matter thoroughly enough. (See NJ BPU Grants Second Easement for OSW Project.)

She also has expressed concern about the cost of some of the governor’s renewable energy policies, especially the offshore wind projects. In August, she voted against the board accepting a report providing an estimate of the cost of implementing Murphy’s Energy Masterplan. She contended that it ignored key costs in implementing the plan and said “no one should contemplate using this study to inform policy decisions.”

Murphy nominated former Assemblywoman Maria Rodriguez-Gregg, to replace Solomon in April 2022, but later withdrew the nomination.

March 14, 2023October 25, 2023

Overheard at the 2023 NECA Renewable Energy Conference

WALTHAM, Mass. — Maria Robinson, director of the U.S. Department of Energy’s Grid Deployment Office, gave an update last week on the work her team has been doing since the office’s launch last year.

Speaking at the Northeast Energy and Commerce Association’s Renewable Energy Conference, held March 9 at the Waltham Woods Conference Center, Robinson painted a picture of a department that’s hard at work looking for the country’s biggest grid challenges and ways to solve them.

The office is working to allocate a great deal of funding from the Infrastructure Investment and Jobs Act, according to Robinson.

“We’re seeing so much funding flowing to areas that are in desperate need of economic recovery and ensuring that they are being … rebuilt at least back to 21st century standards,” she said.

The office is also getting down to business on transmission permitting, and she noted that the Northeast has plenty of practice at dealing with the complexities and politics.

“Here in New England we have experience with individual communities interacting with transmission lines a little differently than others might,” she said.

But she also gave a shoutout to the region’s collaborative memorandum of understanding on offshore wind. (See New England States Group Up To Push For Federal Transmission Funding.) The states are looking to win federal funding from the Grid Resilience and Innovation Partnerships (GRIP) Program.

“That’s the type of exciting innovative project that we’re thrilled to see applying,” Robinson said.

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Amit Barnir, vice president of U.S. network infrastructure at Zenobe | © RTO Insider LLC

Robinson gave one other key update last week, on the process of preparing to work on projects in National Interest Electric Transmission Corridors (NIETC). She said the triennial state-of-the-grid study is a precursor to the NIETC work. The draft version of the study is out for comment now and will be finalized by November.

“At that point in time, our hope is to be able to start opening up for potential applications for those corridors,” Robinson said. “We’ve already heard a lot of interest from private developers, who are more than ready to start that application process.”

State of Renewables in the Northeast

Another panel at the conference discussed the opportunities and challenges for different types of renewables in the Northeast.

Every panelist agreed that there is a lot of promise for nearly every clean technology in the region.

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Katie Theoharides, head of U.S. Offshore East for RWE Renewables | © RTO Insider LLC

“The signs are great. There’s a lot of activity from a jobs perspective. I would characterize it as an exciting time to be in solar,” said Mark Sylvia, chief of staff at BlueWave Solar. “When you think about the Northeast and what’s been accomplished over a very short time, we have a really good story to tell.”

Amit Barnir, vice president of U.S. network infrastructure for storage developer Zenobe, agreed.

“The Northeast is interesting because we’re finding market-based solutions for energy storage,” he said.

And in offshore wind, Northeastern projects have been setting the bar in what is largely a “homegrown industry,” said Katie Theoharides, head of U.S. offshore in the Eastern U.S. for RWE renewables.

“We also have a workforce which is building up and ready to go, and the federal government has come in line and set bold targets as well as releasing historic lease areas in rapid succession,” she said.

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Nickie Collard-Andrade, Avangrid | © RTO Insider LLC

The workforce development piece is key to the success of offshore wind, said Nickie Collard-Andrade, a senior workforce development coordinator at Avangrid.

“Even in the short time I’ve been involved, things have changed dramatically, specifically in workforce development. When I started, it was hard to get people to buy in that it was really happening. The dynamic has changed, and there are more individuals contacting us,” she said.

But there are headwinds for each segment of the Northeast’s clean energy industry too. Most of them have to do with interconnection, the grid and regulation.

“The general approach in the Northeast has started with utilizing existing rules, both wholesale interconnection tariffs and retail tariffs,” Barnir said. “The challenge that we have run into is that energy storage is not just generation; it’s load as well. The rules that are in place kind of only look at it in one direction.”

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Mark Sylvia, chief of staff at BlueWave Solar | © RTO Insider LLC

Sylvia offered a similar perspective for solar.

“Chief among the challenges we face is the grid and the interconnection process. There’s a misalignment between these very aggressive goals governors have set in their states and where we are in upgrading the grid,” he said.

For wind, political and personal views of the technology are an obstacle.

“There are a lot of fears about new technology. How do we make it something that’s approachable and highlights the benefits?” Theoharides said.

She suggested building more political support by bringing oil and gas resources from the Gulf Coast to bear on the Northeast’s offshore wind efforts.

March 14, 2023

NYSERDA Signs MOUs to Explore Renewable Projects in Closed Landfills

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

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

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

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

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

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

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

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

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

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

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

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

March 14, 2023

Orsted, Eversource Propose Revolution Wind 2

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

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

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

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

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

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

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

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

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

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

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

March 14, 2023February 1, 2024

NY OSW Developers Propose Collaboration with GE

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

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

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

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

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

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

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

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

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

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

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

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

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

March 14, 2023

PJM OC Briefs: March 9, 2023

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

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

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

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

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

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

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

Updated Information on Winter Storm Generator Outages

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

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

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

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

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

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

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

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

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

PJM Drafting Comments on Virginia Environmental Rule Change

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

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

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

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

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

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

Transmission Outage Coordination Proposals Discussed

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

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

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

The revisions the IMM is proposing in its package include:

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

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

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

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

March 14, 2023April 11, 2024

Illinois Commerce Commission Chair Announces Resignation

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Michael Madigan, former speaker of the Illinois House | Illinois Legislature

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

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

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

Madigan’s trial is set for April 2024.

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

March 13, 2023December 10, 2023

PJM PC/TEAC Briefs: March 7, 2023

PC Discusses Attachment M-3, Transmission Upgrade Timeline

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

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

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

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

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

Update on RTEP Window 3

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

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