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September 28, 2024

JFK Airport Adding Solar/Fuel Cell Microgrid

New York’s John F. Kennedy International Airport is planning an 11.34-MW microgrid powered by solar and fuel cells to cut emissions and continue operations during power outages.

The plan is part of the replacement of three international terminals at JFK with New Terminal One — a 2.4-million-square-foot facility with a $9.5 billion price tag.

It includes rooftop solar panels with 7.66 MW of generating capacity; fuel cells with 3.68 MW capacity; and batteries rated at 2 MW/4 MWH.

The microgrid will be configured in four separate systems that will be connected to the power grid but also able to function independently and to power the airport if needed. The project will use re-claimed heat to generate chilled water and heating hot water and is expected to result in a 38% reduction in greenhouse gas emissions.

AlphaStruxure on Thursday announced the agreement to design, build and operate the microgrid. The Boston-based company is a joint venture of investment firm Carlyle and energy infrastructure firm Schneider Electric.

No price tag was announced for the microgrid, which will operate under an energy-as-a-service contract.

Construction of New Terminal One began in September. The first gates are expected to open in 2026, and completion is targeted for 2030.

The more than 13,000 rooftop solar panels will be the most at any U.S. airport and will make JFK the first transit hub in the New York City region that can function off-grid during power interruptions.

Many military airfields have microgrids, and a growing number of civilian airports are adding such capacity. Pittsburgh International Airport in 2021 said it became the first airport in the world to be fully powered by an on-site microgrid.

As at JFK, the Pittsburgh microgrid was built, paid for and operated by an outside company — Peoples Gas. A notable difference is that the 20-MW system relies on five generators burning natural gas from on-site wells to supplement its roughly 10,000 solar panels.

The zero-emissions microgrid at JFK will mesh with the decarbonization goals of the Port Authority of New York and New Jersey, which operates the airport.

New Terminal One CEO Gerrard Bushell said “sustainability and resilience” are central to the airport’s overhaul.

“This is future-focused infrastructure that will facilitate the transition away from fossil fuels and sets a new standard for large-scale renewable development in New York and in the air transit sector,” he said. The partnership with AlphaStruxure also provides New Terminal One with price certainty, insulating the terminal from volatile energy markets, he added.

NYISO Slaps NextEra for Lobbying for OSW Tx Projects

NYISO CEO Rich Dewey has rebuked NextEra Energy Transmission New York (NYSE:NEE) for attempting to “lobby” the grid operator to award it transmission projects to connect offshore wind projects to Long Island.

“The NYISO cannot, under its applicable rules, select a project based upon political, parochial or commercial interests,” Dewey said in a Jan. 5 letter, which was first reported by POLITICO. “Grassroots lobbying efforts and media coverage are simply not part of the NYISO’s evaluation of the more efficient or cost-effective solution” to the transmission needs identified by the Public Service Commission.

In August 2021, the ISO solicited projects to add “at least one bulk transmission intertie cable to increase the export capability of the [Long Island Power Authority]-Con Edison interface, that connects NYISO’s Zone K to Zones I and J to ensure the full output from at least 3,000 MW of offshore wind is deliverable from Long Island to the rest of the state” and upgrades to associated local transmission facilities to accommodate the offshore export capability.

Of 19 proposals received from four developers, the ISO last April identified 16 “viable” projects, including nine from NEETNY’s New York Renewable Connect. LS Power, Anbaric Development Partners and the New York Power Authority/New York Transco also made the short list.

Long Island Offshore Wind Projects Under Development (NextEra Energy) Content.jpgLong Island offshore wind projects under development | NextEra Energy

 

NEETNY’s website for the project includes seven “letters of support” from labor unions, elected officials and others.

The New York State Laborer’s Organizing Fund, for example, said “NEETNY is the only potential developer that has actively reached out to the local labor communities where these lines will be constructed to pledge their commitment to good union jobs and involved us in their process.”

The “Western New York Delegation,” which includes three state senators and two assemblymen, praised the company for its “extraordinary level of communication and capability” in building the 20-mile Empire State Line, the first competitively bid transmission project in the state.

None of the other competitors’ project websites included such testimonials.

In an email to RTO Insider, Kevin Lanahan, NYISO’s vice president of external affairs and corporate communications, said “the independence of the NYISO is paramount.”

“This process, as with much of our work, requires that decisions are made according to an impartial analysis of facts and data, as stipulated in our tariff,” and furthermore “the outcome is critical to the climate goals of the state and reliability of the power grid,” which is why “when attempts to introduce outside influence into the decision-making process became apparent, we determined the prudent course of action was to remind all participants of the criteria being considered,” Lanahan said.

After initially declining to comment, NEETNY told RTO Insider late Wednesday that it would comply with the ISO’s rules. 

“As with any project, we always reach out early to the local community and key stakeholders to explain the project need, gather feedback and establish an ongoing dialogue so that if our proposal is selected for construction, we can quickly begin engaging with local partners to incorporate their input,” NEETNY President Richard Allen said in a statement.

“NextEra Energy Transmission New York is grateful to be a participant in the New York Independent System Operator’s Public Policy Transmission Needs process, and we are committed to continue following the processes they have set forth.”

NYISO Management Committee Briefs: Jan. 25, 2023

CRIS Revisions Approved

NYISO’s Management Committee on Wednesday approved the ISO’s proposed tariff revisions related to the expiration and transfer of capacity resource interconnection service (CRIS).

The multiyear effort intends to enhance CRIS rules, with the objective of spending 2023 finishing the functional software requirements necessary to allow the ISO to track partial CRIS expirations.

The proposals seek to facilitate increased capacity deliverability by lowering the cost of new entry into the capacity market for an internal generator or an unforced capacity deliverability rights (UDR) facility looking to either transfer their CRIS rights to a same-location unit or expire their partial CRIS rights.

NYISO also adjusted the CRIS retention rules by enabling deactivated facilities to simply notify the ISO at any point that they will voluntarily relinquish their CRIS.

The Long Island Power Authority continued to object to the changes, saying they “do not address their concerns with CRIS expirations associated with interregional transmission ties with UDR,” while three other organizations abstained from the vote. (See ‘CRIS Revisions Advance,’ NYISO Business Issues Committee Briefs: Jan. 18, 2023.)

The proposals now move to the Board of Directors for approval. NYISO anticipates filing the rules with FERC before the end of the first quarter.

External and Virtual Transaction Errors

Sheri Prevratil, NYISO counterparty and credit risk manager, told stakeholders that the ISO identified typographical errors in the tariff language related to changes to credit requirements for external and virtual transactions, approved last year. (See ‘Credit Requirements on Virtual Transactions,’ NYISO Management Committee Briefs: Nov. 30, 2022.)

Prevratil said the two errors “changed one digit in the import supply table and one digit in the virtual supply table,” though these “did not affect the analysis presented to the MC, and [the ISO has] already updated the presentation and tariff language” accordingly.

In response to a question from Howard Fromer, who represents Bayonne Energy Center, Prevratil confirmed that the tariff changes have not yet been filed with FERC and said NYISO intends to first seek board approval for them in February.

Panel Sees Vital Role for California Offshore Wind

As Californians ponder how the state can achieve a 100% clean energy future while maintaining electric reliability, the chair of the California Energy Commission this week offered a two-part solution.

“Offshore wind coupled with storage is how we do that,” CEC Chair David Hochschild said. “Those two things to me go hand-in-hand.”

Hochschild’s comments came Monday during an offshore wind webinar hosted by the California Natural Resources Agency. One listener asked Hochschild if there’s a guarantee that the state will stop using “the dirtiest forms of energy” once offshore wind is deployed.

Hochschild noted that state law requires all electric retail sales to come from renewable and zero-carbon resources by 2045. At the same time, he said, “the paramount issue is reliability.”

The CEC chair spoke enthusiastically about offshore wind, which he said could power a home for a day with a single turbine rotation.

“In my judgment, after rooftop solar, offshore wind is the lowest-impact form of electric generation in the world,” Hochschild said. And offshore wind is “highly aligned” with the late afternoon and early evening hours when power is most needed, he said.

The webinar was moderated by Natural Resources Secretary Wade Crowfoot as part of his Secretary Speaker Series. Crowfoot said more than 500 people tuned in to the session.

Optimizing Locations

For California offshore wind, floating turbines would be 20 to 30 miles off the coast — a location with potential environmental advantages.

“We are very pleased … that this floating technology is able to push projects 20-plus miles from shore,” said webinar speaker Kristen Hislop with the Santa Barbara-based Environmental Defense Center. “Many environmental groups are very concerned about projects closer to shore.”

Hislop said the nonprofit is optimistic about offshore wind’s potential to help California fight climate change, reduce air pollution and improve energy reliability. At the same time, she said, choosing offshore wind sites should consider species and habitat data and not just wind speed and technical considerations.

“We don’t want to see projects inadvertently impact migrating whales, birds and bats, sea turtles, sharks, fishes and other animals that rely on the California coast,” Hislop said.

Another webinar speaker was state Sen. John Laird (D), whose Central Coast district includes the site of the Diablo Canyon nuclear power plant.

Laird said he took part in negotiations over postponing the retirement of Diablo Canyon’s two reactors, which had been planned for 2024 and 2025. The state is now eyeing a 2030 closure date for the plant.

“I helped fashion that deal in a way that if there was going to be an extension, it would be just extended to the time that offshore wind was coming on, so that we could transition the transmission in that area to use [for] the offshore wind,” Laird said.

First Auction Completed

Last month, the U.S. Bureau of Ocean Energy Management held an offshore wind auction for five leases off the Northern and Central California coasts. The auction, the first for the West Coast, brought in $757 million from the five winning bidders combined. (See First West Coast Offshore Wind Auction Fetches $757M.)

The five lease areas — three off the Central Coast in the Morro Bay Wind Energy Area and two off the Northern California coast in the Humboldt Wind Energy Area — have a total capacity of up to 4.6 GW.

That’s far short of the state’s goal of 25 GW of offshore wind capacity by 2045, and some are already thinking about the next auction.

“We need to move quickly to develop siting plans for the next set of call areas,” said Adam Stern, executive director of Offshore Wind California, an industry coalition.

Stern pointed to planning areas off the coast of Mendocino and Del Norte counties, saying there’s potential for another auction within two years. He said stakeholder involvement is crucial.

“It’s critical that all of the constituencies that are represented on this call are part of this discussion,” Stern said.

That theme was emphasized throughout the webinar.

“How do we get this done as quickly as climate change demands?” Crowfoot said in recapping the offshore wind conversation. “But in a way that’s actually inclusive and thoughtful and careful to avoid and mitigate impacts.”

Berkeley Lab: Wind Generation Needs More Flexible FTRs

Berkeley Lab researchers say growing renewable generation means it’s likely time to retool wholesale markets’ designs of financial transmission rights (FTRs).

In a study released Monday, “Rethinking the Role of FTRs in Wind-Rich Electricity Markets in the Central U.S.,” Lawrence Berkeley National Laboratory said wholesale markets should consider establishing more flexible FTRs that mimic variable generation profiles to better match congestion rents and payouts. The researchers said more tailored designs would be especially helpful in the wind-rich MISO, SPP and ERCOT markets.

“For an ISO to remain revenue neutral, congestion rent should equal the payout of the FTRs,” they said. “Linking FTR payout to the actual utilization of the grid can improve the match between congestion rent and FTR payout.”

Berkeley said wind generators don’t realize much benefit from FTRs as they’re currently designed and recommended improved hedging mechanisms to lower locational basis risk. Congestion often creates divergences in wholesale market prices between individual pricing nodes and trading hubs; the researchers said fluctuations in locational basis can hurt a generator’s bottom line, deter investors and ultimately slow renewable energy development.

“Conventional FTRs … are structured around an unvarying or fixed contract capacity, which is not particularly suited to generators with varying output,” the report said.

Berkeley researchers recommended the three grid operators design FTRs that can fit variable resources’ operational characteristics. They suggested markets develop wind FTRs, where volume varies based on an hourly systemwide aggregate wind profile. A wind generator could then purchase an FTR for a certain capacity, a portion of which would be dispatched based on the day-ahead schedule. The remainder would then be returned to the RTO or ISO at “no cost or profit to the wind generator.”

Berkeley also suggested FTRs could become dispatch-contingent so that they would only pay the price difference when the generator is operating or that markets institute “cap FTRs” (where the payout is the difference between the load and generator nodes), but only when the node’s price is above a predefined strike price.

The research team acknowledged that “adapting FTR auctions to include new products is not trivial.”

Berkeley said that after studying 2015-2019 data from MISO, SPP and ERCOT, the researchers said it’s clear that wind plants “face a disproportionately larger” locational basis.

“Empirical data from markets in the central U.S. confirm that wind plants face the largest, and among the most volatile, generation-weighted basis of any type of generator,” the report said. “Because wind plants tend to be located far from load centers, they rely on the transmission network to deliver power and are exposed to congestion when transmission capacity is limited.”

The research team said while annual fixed-volume FTRs “can nearly eliminate basis for most conventional generators” with steady output, they’re “less effective for reducing the average basis for wind.”

A fixed-volume FTR reduces wind’s locational basis by $1 to $5/MWh, according to the report, but still leaves wind generators with an average of $1.80 to $3.50/MWh of “residual basis” across the three markets. A wind FTR, on the other hand, could drive down that residual basis to less than $1/MWh.

A financial consulting firm recently concluded MISO needs to update its auction revenue rights and FTR market to reflect the system’s changing flow patterns. Among other recommendations, London Economics International suggested MISO tailor its products to an evolving supply mix and load patterns by offering morning, afternoon, evening and night options. (See Financial Firm Finds MISO FTR Market Needs Work.)

MISO, Stakeholders Debate Lower Congestion Limit

CARMEL, Ind. — MISO appears set to limit transmission congestion by instituting a lower system impact threshold on interconnecting generation that is all but certain to prompt more network upgrades.

“We’ve received a lot of feedback on this item,” MISO’s Kyle Trotter said during a Planning Advisory Committee meeting Wednesday. “We continue to believe that this change will bring positive impacts to stakeholders and future system reliability.”

The RTO’s proposal might dim prospects for some new generator interconnection requests. (See MISO Insists it can Handle Record-setting Interconnection Queue.)

Last summer, MISO suggested halving new generation’s allotted distribution factor’s (DFAX) effect on transmission from 20% to 10% for its basic and unguaranteed energy resource interconnection service (ERIS). (See MISO Recommends Lower Distribution Factor to Address Congestion.)

Trotter said the change will result in upgrade costs being shared among more interconnection customers and fewer unaddressed reliability issues being passed on to later queue cycles or surfacing in MISO’s annual transmission expansion plans. He also said the likely additional upgrades will help reduce “future reliability issues and overloaded equipment.”

The grid operator responded to a request from MISO South members and studied a 5% DFAX limit but decided the threshold would be too drastic. Staff said a 10% limit provides a good balance without being too aggressive.

Some stakeholders have said that it’s premature to lower the DFAX threshold across the board when MISO hasn’t yet put together a long-range transmission plan portfolio for the South region. Staff have marketed the LRTP portfolios as being able to support more generation interconnections.

Generation developers maintain that a tighter DFAX threshold is punitive and places even more responsibility for system planning on interconnection customers. Some stakeholders have argued that MISO is conflating transmission reliability with real-time congestion costs.

“The plan remains the same,” Trotter said, adding that MISO will begin applying the change to the 2022 cycle of projects entering the definitive planning phase. The revision requires a change to MISO’s business practice manuals.

Several stakeholders complained that staff haven’t studied the possible financial impact to interconnection customers.

“This was sold as a way to reduce congestion,” NextEra Energy’s Matt Pawlowski argued. “I as a NextEra representative don’t know what I’m actually getting with this change. No dollars have ever been shown. I know one thing: My costs are going to be higher. But I’m not sure what I’m going to get for that money. I would love to know what the plan is to actually show that.”

Pawlowski said that the issue was introduced as an economic benefit, but MISO morphed it into a reliability matter.

Andy Witmeier, director of resource utilization, agreed that stakeholders initially raised the issue as an economic one. He said when staff examined the situation, it became clear that the RTO needed to act out of a concern for reliability.

“We’re going to be adding three to four times more generation to our grid than is retiring. So, this is just going to continue. Our stance is that now is the time to make this change. We can’t wait for all these units to come online,” Witmeier said. “Certainly, there are economics at play here, but MISO’s position has always been, ‘This comes down to reliability.’”

“The problem is you’ve not proven anything,” Pawlowski said. “We’ve conflated economics with reliability and come up with reliability because it’s the easier one to pursue. And we’re going to pay those extra dollars not knowing … whether we have better access to the grid. That hasn’t been addressed.”

Witmeier countered that MISO’s reliability analyses of a tighter DFAX threshold turned up “a lot of constraints that we’ve been ignoring.”

Union of Concerned Scientists’ Sam Gomberg said MISO has not performed a cost-benefit analysis to show that a lower DFX cutoff would combat congestion.  

“We don’t know the impact of this change. All of the projects could withdraw, and none of these upgrades could be built,” Clean Grid Alliance’s Rhonda Peters said. “I’m not saying that’s the case. I’m saying we haven’t done an adequate study.”

Peters said that MISO has not contemplated how much generation might drop out because of a 10% cutoff.

Travis Stewart, representing the Coalition of Midwest Power Producers, said the change means that the grid operator should update upgrade estimates for affected interconnection customers.

Witmeier said that IC customers, who consistently withdraw from the queue, should perform their own benefits analysis. He argued that the footprint doesn’t currently have enough customers to buy all 280 GW of the generation in the queue.

“MISO is responsible for setting the reliability standards on congestion from generator interconnection. We’re doing that,” he said.

Sustainable FERC Project’s Lauren Azar has maintained that lowering the DFAX threshold will result in more costs transferred to generators.

“Interconnection is about reliability and not addressing congestion,” Clean Grid Alliance’s Natalie McIntire argued during an October meeting of MISO’s Interconnection Process Working Group. “What’s resulting is congestion in real-time, which is an economic issue. ERIS generators are energy-only and should expect to be curtailed.”

MISO staff contended at the time that the binding constraints interconnections ultimately cause are a reliability issue. They said potential constraints are currently being ignored in the GI process, only to crop up later in the system.

NextEra Changes Leadership at FPL Subsidiary

NextEra Energy CEO John Ketchum on Wednesday pushed back against allegations of campaign finance violations at the company’s Florida Power & Light (FPL) subsidiary.

In a prepared statement made during the company’s year-end earnings call, Ketchum told analysts that an internal review of media reports of alleged violations by FPL is “substantially complete.”

“We believe that FPL would not be found liable for any of the Florida campaign finance law violations as alleged in the media articles,” he said, basing his comment on “information in our possession.”

Ketchum said the media coverage was used in a subsequent complaint filed in October by Citizens for Responsibility and Ethics at the Federal Election Committee. The ethics watchdog named names in its complaint and tracked contributions totaling $1.27 million to federally registered super PACs in 2020.

John Ketchum (NextEra Energy) Content.jpgJohn Ketchum | NextEra Energy

NextEra (NYSE:NEE) plans to seek dismissal of the complaint in the next few weeks, Ketchum said.

“[The complaint] primarily relies on media articles that allege certain violations … by various parties, including, by implication, FPL,” Ketchum said. “We do not believe it is appropriate for a complaint such as this to move forward … we do not expect that allegations of federal campaign finance law violations taken as a whole would be material to us.”

NextEra also announced that FPL CEO Eric Silagy plans to retire after 20 years with the company, 11 as the utility’s top executive. Armando Pimentel, who retired from NextEra in 2019 as CEO of NextEra Energy Resources, will replace Silagy.

Silagy has denied any knowledge of the utility’s alleged involvement in manipulating Florida elections, although leaked messages have shown he was in frequent and detailed communication with his senior staff about influencing a state senate race. Silagy served as senior vice president of regulatory and state governmental affairs before being named FPL’s CEO.

Ketchum said NextEra wasn’t making a “connection” between the allegations and Silagy’s retirement but acknowledged the reports may have played a role.

“When you think about all the challenges that he had to overcome, with the hurricanes and high natural gas prices and inflation and supply chain and, you know, the media allegations and all those things, I think it took a toll on Eric that year,” Ketchum said in a response to an analysts’ question. “The way I look at it is it’s a little earlier than I would have hoped Eric would have wanted to do it.”

Shares Plunge

The earnings discussion, leadership changes and NextEra’s mixed results led to nearly a 9% drop in the company’s stock price. Shares closed at $76.59 Wednesday, down $7.31 from the previous close.

NextEra reported a fourth-quarter earnings of $1.52 billion ($0.76/share), compared to $1.20 billion ($0.61/share) a year ago.

For the full year, earnings were $4.157 billion ($2.10/share), up from $3.57 billion ($1.81/share) in 2021.

Operating revenue was up to $6.16 billion from $5.05 billion in 2021. However, analysts had expected $6.3 billion.

NextEra Energy expects 2023 earnings in the range of $2.98-$3.13 per share. The midpoint, $3.05 per share, is lower than the Zacks Consensus Estimate of $3.11.

Ketchum said the Inflation Reduction Act’s passage leaves NextEra “better positioned than ever before to offer low-cost renewables and other clean energy solutions” beyond 2030. He said the company is extending its adjusted EPS growth expectations to $3.63-$4.00 for 2026.

“We will be disappointed if we are not able to deliver financial results at or near the top end of our adjusted earnings per share expectations ranges,” Ketchum said.

New England States Group Up To Push For Federal Transmission Funding

The New England states have united to seek federal funding to help strengthen the region’s transmission to accommodate electricity from offshore wind projects and Canada.

As a coalition, the states have put forward concept papers to the U.S. Department of Energy, asking to be considered for funding for transmission projects as part of DOE’s new Grid Innovation Program, which is giving out up to $2 billion in funding in its first cycle.

The program will eventually give out up to $250 million per project, aiming to “support projects that use innovative approaches to transmission, storage and distribution infrastructure to enhance grid resilience and reliability.”

New England’s states see themselves as strong candidates, pointing to the region’s unique energy security risks and natural gas reliance.

In a joint press release, the states said they are looking to pursue transmission investments that “reduce the region’s reliance on imported fossil fuels in winter months, help insulate electricity customers from the wild swings in the fossil fuel markets currently leading to high electricity prices throughout New England and take advantage of diverse energy sources.”

Their first proposal is a partnership between states, transmission providers and wind developers called the Joint State Innovation Partnership for Offshore Wind. If given federal funding, it would “proactively plan, identify, and select a portfolio of transmission projects needed to unlock the region’s significant offshore wind potential, improve grid reliability and resiliency, and invest in job growth and quality.”

In a separate submission led by Vermont, the states are also asking DOE for funding for the New England Clean Power Link, a proposed 1,000-MW transmission line between Québec and Vermont that would increase imports of Canadian hydropower.

The NECPL, under development by Blackstone subsidiary TDI New England, has received the permits it needs to bury two six-inch wide cables for around 150 miles in Vermont, including under Lake Champlain. But there’s no contract yet for the power that would be delivered, and construction on the project has yet to commence.

DOE will be evaluating the applications over the next few weeks and is expected to invite some of the applicants to submit full proposals for funding, which would be due in May.

“We are hopeful that DOE views these concept papers favorably, and Connecticut and its partners stand ready to turn the proposals we’ve submitted into tangible models of climate action and its numerous benefits,” said Katie Dykes, commissioner of the Connecticut Department of Energy and Environmental Protection.

OSW Transmission Planning Must be Interregional, Networked and Start Now

The U.S. will require a massive mobilization of resources and unprecedented collaboration among federal, state and regulatory authorities to build the transmission needed to the meet its aggressive offshore wind goals, a new report says.

Those goals include President Biden’s call for 30 GW of offshore wind by 2030 and a national target of 110 GW by 2050.

Such “proactive and holistic” planning efforts could save U.S. consumers $20 billion and reduce environmental and community impacts by 50%, according to the report, “The Benefit and Urgency of Planned Offshore Transmission,” compiled by The Brattle Group for a consortium of clean energy and grid advocates.

“Compared to the current process of developing and interconnecting one OSW generation project at time, each with its own cables to shore, a coordinated comprehensive transmission plan could unlock numerous efficiencies and benefits unavailable under current processes,” the report says.

But “to achieve these benefits, state and federal policymakers, industry regulators, system operators and market participants must expeditiously address” existing obstacles, such as interconnection and permitting reform, the report says. “Even modest delays in developing and implementing actionable plans for both near- and long-term transmission investments substantially reduces [sic] the benefits of such planning efforts.”

For example, the report cites a study done by National Grid in the United Kingdom finding that a delay of five years in long-term transmission planning would cut benefits — including $7.4 billion in costs savings — in half.

“If we don’t carefully plan, it’s not just the next 10 to 15 years,” said Johannes Pfeifenberger, a principal at The Brattle Group and lead author of the report, speaking at a launch webinar on Tuesday. “But with a view to 2040 and 2050, we are really prone to severely limit our future options.”

The report’s to-do list is daunting. In the next year alone, federal and state governments must increase funding and staff for offshore transmission planning, and the Internal Revenue Service must clarify the offshore wind tax credits in the Inflation Reduction Act. Offshore developers are specifically looking for the IRS to confirm that a project’s transmission infrastructure will qualify for the tax credit.

At the same time, states will have to come together to form multistate “transmission authorities,” which will “facilitate the planning and procuring of effective regional and interregional transmission solutions,” the report says. Federal leasing processes should be changed to lay out “offshore cable routes between projects,” and “network ready” standards for offshore substations and cables must be developed to ensure interoperability between projects.

A range of funding opportunities and incentives in the IRA and Infrastructure Investment and Jobs Act should be leveraged to jump-start these and other mid- and long-term recommendations in the report. Potential funding sources in the IRA include $760 million to help with siting of interstate and offshore transmission and $2 billion in financing, such as loan guarantees, for transmission projects the Department of Energy designates as being “in the national interest,” the report says.

But, Pfeifenberger said, some IRA funds, such as offshore wind tax credits, sunset in 10 years, which is about how long it takes to permit and build an offshore project and transmission; hence, the need for immediate action. “We won’t be able to take advantage of [IRA funding] unless we start to plan for what it is that we need,” he said.

A Burning Fuse

A joint project of the Natural Resources Defense Council, GridLab, the Clean Air Task Force, the American Clean Power Association and the American Council on Renewable Energy, the report’s call for urgency is rooted in the confluence of the expansion of offshore wind in the U.S. and the federal funding opportunities in the IRA and the IIJA.

In addition to Biden’s 30 GW, states on both the East and West coasts have set offshore targets totaling 77 GW by 2045, and a range of studies are projecting the U.S. could need as much as 460 GW of offshore wind to meet its 2050 climate goals, the report says.

Connecting these projects to the onshore grid requires laying underwater cable and finding onshore points of interconnection (POIs) that may run across beaches or through coastal communities, as well as interregional high-voltage DC transmission lines to get power to load centers. Projects and their transmission can take a decade to site, permit and build, making the need for forward planning more urgent, as does the siting of multiple projects near each other, as is now occurring on the East Coast, the report says.

“The days of low-hanging fruit where you have near ready-made POIs are really done, and we’re starting to brush up against some really tough nuts to crack in terms of interconnecting these resources,” said Robert Golden, senior adviser for clean energy infrastructure at the White House. “The opportunity is huge to deliver for customers, but this is really a bit of a burning fuse, and if we don’t move quickly a lot of the benefits … can vanish off the table.”

“Current interconnection points are not sufficient to accommodate all the offshore wind that is expected to come online over time,” agreed Lopa Parikh, head of electricity policy for offshore wind developer Ørsted, which is currently working on eight projects off the Atlantic coast. “So, any proposals for transmission projects that are considered really need to consider the full scope of potential offshore wind development to ensure that they can be accommodated over the long run. … This is especially true since most of the offshore wind is currently being developed close to load centers, which greatly increases the need to create more efficient transmission planning.”

The benefits of such coordinated planning could include a 60% to 70% reduction in the need to upgrade onshore transmission lines or run lines across beaches or through coastal communities. The amount of underwater cable needed for projects could also be cut by as much as 2,000 miles, the report says.

“Every time you have to go back and disturb [an] area, that impacts the communities,” said Suzanne Glatz, director of strategic initiatives and regional planning at PJM. “There’s a lot of value to be extended if we can minimize the number of times we have to go back to those areas.”

Suedeen Kelly, a former FERC commissioner and now a partner at law firm Jenner and Block, believes that offshore wind development should be seen as a “unique effort in America. … We shouldn’t necessarily try and pigeonhole this planning process into existing frameworks and existing silos.”

“We don’t really know what the best configuration of an offshore grid is,” Pfeifenberger said. “Is it just meshed radial lines? Is it a backbone? Is it some sort of combination of these things? We need a planning process to figure out what is the best configuration for a given region.”

At the same time, Pfeifenberger sees interregional offshore transmission planning as providing new opportunities for improving grid reliability and resilience. “We can use the offshore infrastructure to reinforce the onshore grid, and there is a lot of interregional transmission that studies find would reduce total costs faced by consumers significantly, and offshore links may be the most cost-effective way to provide that regional and interregional transfer capability.”

He also envisioned “multipurpose connectors … that not only bring offshore wind to shore but also create reinforcement to the onshore grid,” he said. The problem, however, is that the HVDC lines that would be used in such networks have a higher capacity than the standard maximum most RTOs and ISOs can handle, even in a “most severe single contingency,” Pfeifenberger said.

“That kind of [HVDC] network would really improve the reliability of delivering offshore wind. It allows for higher capacity transmission cables that are … able to reroute power and avoid large impacts on individual grid nodes,” he said.

Switching Trains

The report’s call for urgent action on transmission planning for offshore wind comes at a time when FERC and RTOs/ISOs are all wrestling with planning and interconnection issues, though their focus has been regional, rather than the interregional coordination the report sees as critical. In addition, Pfeifenberger said, these bodies will also need to work on new frameworks for regulations, contracts and markets.

Brattle has done a number of studies advocating for coordinated planning for offshore wind for New York and New England, comparing the cost and impacts of traditional, siloed planning with a holistic, networked approach in which multiple projects can be linked or can share cables and POIs.

“Before we have a networked offshore grid, we will need the regulatory and contractual framework for shared network operations,” he said. “The regional grid operators need to tune up their operations and market design because right now they are not ready to handle HVDC links, either within their region or across regions,” he said.

FERC’s anticipated rulemaking on regional transmission planning “will be very helpful, at least if the final rulemaking is anything like the [Notice of Proposed Rulemaking] itself,” Pfeifenberger said. “However, FERC rulemaking won’t be effective unless there is also leadership from the regional grid operators and the states.”

The lack of collaboration between states and grid operators was one of the factors behind the failure of FERC Order 1000, the grid planning order the commission issued in 2011, he said.

“We’re basically trying to develop a process that allows us to switch trains while both trains are moving at high speed from the current process to a better planning process, and that requires a lot of additional thought and preparation,” Pfeifenberger said.

Not yet finalized, the NOPR would direct transmission providers to revise their planning processes to, among other things, identify infrastructure needs on a long-term, forward-looking basis and propose a list of benefits on which they would base their selections of proposed projects to meet those needs. It has had a mixed reception among industry stakeholders. (See Battle Lines Drawn on FERC Tx Planning NOPR.)

Following the departure of Richard Glick as FERC chair, the commission is now potentially deadlocked with two Democratic and two Republican commissioners, leaving the future of the rulemaking uncertain.

Kelly sees the regional NOPR as a first step but stressed that it will not cover the kind of interregional planning needed for offshore wind. FERC could, she said, “play a pivotal role initially by becoming a national forum for the provision of information prior to talking about any kind of regulation.”

By hosting a series of technical conferences, FERC could provide “a single place where interested developers, states [and other] stakeholders could come” to discuss the issues, she said.

Equal Access Is Key

But developing any new transmission planning processes must not slow down or delay projects already underway, Parikh said. “Making changes to projects that have already been awarded could negatively impact the viability of these projects and the ability for them to interconnect in a timely manner.”

PJM’s state agreement approach (SAA) with New Jersey is one way forward, Glatz said. Under the SAA, PJM ran a solicitation for the New Jersey Board of Public Utilities for transmission projects to connect 6,400 MW of approved offshore wind projects to the grid. According to the report, the solicitation and the resulting projects chosen by the BPU saved the state $900 million. (See NJ BPU Oks $1.07B Transmission Expansion.)

She also pointed to PJM’s interconnection reforms, recently approved by FERC, that will shift the RTO from its current first-come, first-served methodology to instead studying new service requests with a first-ready, first-served approach that clusters proposed projects together to determine network impacts and allocate network upgrade costs. (See FERC Approves PJM Plan to Speed Interconnection Queue.)

The reforms mean “we can be looking out to not only the first project, what it would take to interconnect that one, but also the one after and the one that comes two or three years after that,” Glatz said. “What is that holistic solution to meet the interconnection of those projects?”

But forward planning also carries certain risks. “You are planning for multiple projects, some of which may not be very far along or even yet entered into the interconnection queue,” she said. “So, there’s a possibility that those will not materialize, and you may have more transmission built that could be more costly.”

Glatz also stressed the independent role RTOs play as “organizations that plan the system to meet the needs of all system users, which would mean studying all generation requests in a nondiscriminatory manner and to provide equal access to all of them.”

The RTOs’ wholesale markets must also provide equal, nondiscriminatory access, Glatz said. “Assuring that the planning process still serves that purpose is really key to anything we’re going to consider in terms of potentially prioritizing any resources.”

Members Press NERC to Expand Comments on IBR Standards

Members of NERC’s Standards Committee moved forward a slate of standards development projects at their monthly conference call Wednesday after moving to address concerns about stakeholders’ ability to provide feedback.

The biggest debate revolved around the first standards action, which proposed to accept a draft standard authorization request (SAR) to revise reliability standard EOP-004-4 (Event reporting) to ensure that events involving inverter-based resources (IBR) are reported to regional entities or other responsible authorities.

The SAR was developed in response to NERC and WECC’s joint white paper on the widespread reduction of solar output in Southern California on July 7, 2020. NERC’s Reliability and Security Technical Committee (RSTC) endorsed the draft SAR at its meeting on Dec. 6. (See “Members Approve IRPS SARs,” NERC RSTC Briefs: Dec. 6-7, 2022.)

The action before the committee on Wednesday was to accept the draft SAR and authorize NERC to solicit SAR drafting team members and post the proposal for a 30-day informal comment period. However, Southern Co.’s Jim Howell, noting “some feedback from my segment [over] concerns with what this might involve,” suggested modifying the proposal to post the SAR for a formal, rather than informal, comment period.

Latrice Harkness, NERC’s manager of standards development, responded that a formal comment period was unnecessary because industry already had a chance to influence the draft SAR when it was before the RSTC. She added that a formal comment period would require the SAR drafting team to provide a response to stakeholders when it returns to the committee with the final SAR. This would not be required for an informal comment period.

In either case, the team would not be required to revise the SAR in response to comments.

Howell insisted that the committee should err toward giving as many opportunities for industry input as possible.

“There’s still quite a bit of folks not necessarily plugged in to those committees that may have some valid comments about the SAR itself,” Howell said. “I do think [we] would be better served to have a formal comment period where there’s more interaction between the drafting team and the comments up front.”

Marty Hostler, reliability compliance manager for Northern California Power Agency, supported Howell’s proposal, saying that “there are just a host of initiatives out there by FERC [and] NERC on IBRs,” and that it would be inappropriate to move forward with yet another standards project “until we get all these other comments in … from the other IBR initiatives.”

Hostler said a formal comment period would provide a chance “to have industry vet what their opinions are.” Kent Feliks of American Electric Power and William Chambliss of the Virginia State Corporation Commission also voiced support for the idea, with Chambliss seconding Howell’s formal motion to switch from an informal to a formal comment period. The motion passed the committee unanimously.

Other Standards Actions

The committee’s next item also concerned IBRs, with a proposal to accept a draft SAR to “address IBR performance issues” either by creating a new standard or by modifying PRC-004-6 (Protection system misoperation identification and correction).

Like the earlier draft SAR, this proposal was also endorsed by the RSTC at its December meeting. Hostler again expressed misgivings about the SAR, asking why the committee needed to consider two separate projects both intended to address IBRs. Vice Chair Todd Bennett, of Associated Electric Cooperative Inc., responded that the two SARs had very different goals, with the former intended to address reporting of IBR-related incidents and the latter intended to mitigate performance issues within IBRs once they have been detected.

Aside from Hostler’s questions, few misgivings were expressed for this item. Howell explained that he was “not so concerned” about requiring a formal comment period because there is already “a lot of … good information out there from the industry on what this would entail.” The committee voted unanimously to accept the SAR, appoint the drafting team and authorize posting for an informal comment period.

Next up was a proposal to accept two SARs requiring registered entities to perform energy reliability assessments to ensure energy assurance. The SARs were proposed by NERC’s Energy Reliability Assessment Task Force (ERATF) last year and assigned to Project 2022-3 (Energy assurance with energy-constrained resources) at the Standards Committee’s September meeting. Harkness explained that the ERATF and SAR drafting team proposed two SARs to cover risks associated with the operational and planning time horizons separately.

Chambliss abstained from the vote, explaining that “all this work occurred before I got on the committee, and I hadn’t really had a chance to familiarize myself with it.” The proposal — which included appointing the 15 members of the SAR drafting team as the standard drafting team as well as accepting the SAR — otherwise passed without objection.

Also approved without objection was a proposal to appoint the SAR drafting team, including chair and vice chair for Project 2022-05 (Modifications to CIP-008 reporting threshold). The project was also approved at the committee’s September meeting; NERC solicited industry for nominations to the team from Nov. 2 through Dec. 5, receiving 10 nominations whose names were not disclosed at Wednesday’s meeting in accordance with the organization’s confidentiality policy.

Finally, the committee approved a motion to update NERC’s definition of reporting area control error (ACE) as proposed by Project 2022-01 (Reporting ACE definition and related terms). The new definition expands the list of relevant entities and changes certain language to reflect updated NERC terminology.

While no committee members voted against the measure, Robert Blohm of Keen Resources abstained from the vote. He said he was concerned about the committee’s inability to review the final comment form before it is posted, mentioning that he had already expressed misgivings about the lack of questions regarding the definition of ACE Diversity Interchange. Describing this absence as “a serious technical error … that could affect the acceptability” of the ballot outcome, Blohm said he could not “in good conscience” support the motion.

Members Approve Executive Committee Slate

In addition to their standards actions, attendees approved the membership of the Standards Committee’s Executive Committee (EC) for 2023, to serve one-year terms.

According to the Standards Committee’s charter, the EC is to comprise five members including the chair and vice chair — currently Amy Casuscelli of Xcel Energy and Bennett, respectively. At its last meeting, the committee invited those interested in one of the three remaining seats to submit their nominations by Jan. 9. (See “2023 Executive Committee Nominations,” NERC Standards Committee Briefs: Dec. 13, 2022.)

Three committee members nominated themselves prior to the meeting: Venona Greaff of Occidental Chemical, Sarah Snow of Cooperative Energy and Charles Yeung of SPP. Troy Brumfield, regulatory compliance manager at American Transmission, also threw his hat in during the meeting. Members chose Brumfield, Greaff and Snow in the final vote. Bennett thanked the new EC members and encouraged others “to get involved with this committee as much or as little as they like.”