Page 43 – RTO Insider

August 18, 2024

Pathways Initiative Committee Floats Ideas to Protect Public Interest

Protecting the public interest while implementing the Extended Day-Ahead Market (EDAM) and expanding the Western footprint was central to the discussion in a West-Wide Governance Pathways Initiative workshop Aug. 15.

“How are we going to continue to serve the public interest with an expanded footprint and with alternative, different governance?” Alice Reynolds, president of the California Public Utilities Commission, asked.

Members of the launch committee sought feedback on a combination of tools that could protect the public interest across the footprint of the regional organization (RO) the Pathways Initiative seeks to establish.

Beyond regulation by FERC, members discussed five main components that could be integrated into the structure of a new RO, including a stakeholder process, an independent market monitor, consumer advocate engagement, a states committee and an RO board.

In the implementation of an RO board, members emphasized public interest protection language in the articles of incorporation and the charter provisions. Also deemed important: a commitment to expand public benefits by attracting new participants, protecting individual state and local generation preferences and climate policies, holding open meetings and adhering to open records requirements.

Board members should have a history of protecting the public interest in their official roles, said Ben Otto, consultant with NW Energy Coalition and a launch committee member.

“There can be standards of duty for the board that are incorporated, like they have to act to protect public interest, and that is then their obligation when they’re acting as a board member, to follow those requirements and not their own wishes,” Otto said.

The RO also could establish a states committee that would maintain the current Western Energy Imbalance Market Body of State Regulators structure with a charter requiring protection of the public interest. Under this structure, states individually or through the committee could continue to submit 206 pleadings at FERC.

Other aspects of the committee would be having access to market monitor data, having the power to originate a stakeholder initiative with support from half of the participating states or half the load, having a seat on the RO board, and having veto rights over RO board nominations with a two-thirds vote of states and load. A subset of the committee representing one-quarter of states or load could vote to trigger a requirement for a supermajority vote on a particular topic.

Consumer advocates also could play a role by participating in stakeholder processes, having access to market monitor data and obtaining a seat on the RO board.

“This is absolutely necessary to ensure that the board is well informed on consumer issues. Being informed on consumer issues, we think, is key to fulfilling the public interest mission that we’ve laid out here in Pathways,” said Michele Beck, director at the Utah Office of Consumer Services and a member of the launch committee.

Individual consumer advocate offices aren’t resourced enough to participate in these processes, Beck said, creating the need for a central consumer advocate organization that could maintain interaction with RO processes. Launch committee members suggested the creation of a 501(c)(3) organization that could facilitate consumer advocate participation. Beck highlighted the Consumer Advocates of the PJM States (CAPS) program as an example worth replicating.

Launch committee members also highlighted other existing structures within the CAISO model that could be carried forth in the new RO, including the ISO’s Department of Market Monitoring and Market Surveillance Committee.

Additional ‘Tools in the Toolbox’

Stakeholders provided additional ideas for protecting the public interest.

“One other tool that we should have in the toolbox for protecting the public interest is really allowing and enabling the public to participate in our decision making to the extent that it’s appropriate,” said Mark Specht, Western states energy manager at the Union of Concerned Scientists and a member of the launch committee. “Things we might consider would be creating some sort of office of public engagement that would really serve as a resource for folks who are interested in participating and having their voices heard in our decision making.”

Preserving state and local autonomy within regions also was a primary point of conversation given the different laws, policies and preferences within each state.

“We’ve really been thinking about, how do we create a system that explicitly acknowledges and protects the ability for states to keep that authority in place and enables states to really develop their own vision of what the public interest is?” said Kathleen Staks, executive director of Western Freedom and co-chair of the Pathways Initiative. “What tools holistically across the entire regional organization ensure that the regional organization protects the public interest in lieu of a single state statutory requirement like we have with the CAISO today?”

Commissioner John Hammond of the Idaho Public Utilities Commission echoed concern over the challenge of defining the public interest given the array of different players.

“There are obviously common interests in keeping costs low and in reliability, but I worry about when we start getting into policy areas and what impacts that might have on the individual states that have different policies,” Hammond said. “My fear is you start incorporating too many things in the toolbox, you might get a reaction legislatively from particular states … so I think it’s very important that we define exactly what public interest we are trying to protect.”

August 18, 2024August 19, 2024

Corrected: NYISO Operating Committee Briefs: Aug. 15, 2024

The NYISO Operating Committee has approved two study reports and one study scope, all of which involve load projects in northern New York.

The SDC St. Lawrence interconnection study modeled the impact of the 120-MW load project on the local system. NYISO staff found that the project would cause thermal overload that could not be mitigated with adjustment. In sensitivity scenarios, the project caused voltage violations and voltage transfer degradation.

NYISO estimated the cost to build the attachment facility for the interconnection is $55 million, plus or minus 50%, and it would take about 54 months to complete. The cost to mitigate the thermal overload issues and the voltage transfer degradation issues were $33.6 million and $37.5 million. Voltage violations would cost an estimated $2.5 million to mitigate. An additional estimated $39 million would be needed to mitigate thermal issues at the transformer.

The customer asked if there was a different software package that could be used to help reassess costs.

“We can take it back and consider it, but I don’t believe the additional capability of the distributed model at St. Lawrence would resolve these overloads” or alleviate upgrade costs, said Aaron Markham, vice president of operations for NYISO.

In the study report for the Massena Green Hydrogen project, a 110-MW hydrogen electrolysis plant, no adverse impacts to the grid were found. NYISO found that interconnection would be feasible with the construction of a new three-breaker and bus substation. The estimated cost for the interconnection would be about $27.7 million, and the project would take two to three years to complete.

The Cayuga Compute 150-MW data center scoping study was discussed and approved. The study will perform reliability and cost-estimation analysis similar to the reports listed above.

Other Business

The Operating Committee also heard the July 2024 Operations Performance Report. Peak load was 28,990 MW, which set the new summer 2024 peak. Markham said this was because of higher-than-average temperatures.

He noted that NYISO also had to call on the Emergency Response Demand Program and Special Case Resources during the evenings of July 15-16. Markham said they hit scarcity pricing on both days.

“On the 16th of July, a number of severe thunderstorms, including 10 confirmed tornadoes, occurred in the state as the remnants of Beryl passed through,” Markham said. He said that caused simultaneous outages for about 275,000 customers.

“There was a tornado in Buffalo early last week, and from what I saw, that broke the [record for the] number of tornadoes that occurred in the state,” Markham said. “That was 25 back in 1992; we are up to 26 this year.”

The committee also reviewed and approved supplemental manual updates for constraint-specific transmission shortage pricing. These updates to the day-ahead scheduling manual and transmission dispatch operations manual are described here. Drafts may be seen here and here.

Eds: A previous version of this article incorrectly referred to the SDC St. Lawrence as the North Country Data Center.

August 18, 2024August 20, 2024

NYISO Tariff Revisions Include Uncertainty Reserve

NYISO staff have presented tariff revisions that may be deployed as early as the first quarter of 2026 to account for the uncertainty of wind and solar energy forecasts. The filing date with FERC has yet to be determined.

If accepted by FERC, the revisions would add two new items to the tariff, uncertainty reserve requirements and scarcity pricing in 30-minute reserves for the New York Control Area and several downstate zones. These requirements would add a stepwise demand curve to the market.

“Uncertainty reserve requirements for operating reserves are here to account for the forecast uncertainty of node wind and solar energy forecasts,” Vijay Kaki, market design specialist for NYISO, said at the Installed Capacity Working Group meeting Aug. 13.

Kaki explained the uncertainty reserve requirements would be calculated for, and apply to, the day-ahead and real-time markets. For the day-ahead market, the uncertainty reserve would apply only to the 30-minute reserve product. In the real-time market, these new reserves would be calculated for both 10- and 30-minute reserve products.

For the day-ahead market, the reserves would be calculated for each hour of the day, before the day-ahead market run.

“It’s a daily change,” said Kaki, explaining this was based on annual forecast data. “The annual metrics are calculated once a year, and those metrics will be applied to the day and market forecast data on a daily basis.”

The NYISO price scheme is intended to encourage generators to respond quickly to requests for energy to meet reliability requirements. The market would pay more for generators who activate when operating reserves and uncertainty reserves are low.

Revisions to the tariff, along with a consumer impact analysis, are expected to be done by the end of the third quarter.

Winter Reliability Enhancements

After discussing the tariff revisions, NYISO presented the winter reliability capacity enhancement project that tentatively is scheduled for 2025. The idea is to ensure the capacity market provides the correct price signals all year to ensure reliability as New York transitions to a winter-peaking system.

“We’re looking at this project to consider what would be the process for setting winter CAFs [capacity accreditation factors] and would they be any different,” said Michael Swider, senior market design specialist for NYISO.

Swider said the market needed to be evaluated to look for elements that are more affected by a more seasonally differentiated capacity market. Currently there is one installed capacity requirement that is applied to an entire year that is forecast based on annual peak load, which occurs in summer.

NYISO projects the system will transition to a winter peak in the 2030s. The RTO has stated its concerns about fuel constraints occurring in winter, particularly if the system is winter peaking. (See NYISO Braces for the Coming Winter.) Because the current ICAP is calculated based on summer load, NYISO staff worry the current system may cause reliability and market issues.

August 18, 2024

PJM MRC/MC Preview: Aug. 21, 2024

Below is a summary of the agenda items scheduled to be brought to a vote at the PJM Markets and Reliability Committee and Members Committee meetings Aug. 21. Each item is listed by agenda number, description and projected time of discussion, followed by a summary of the issue and links to prior coverage in RTO Insider.

RTO Insider will cover the discussions and votes. See the website and next week’s newsletter for a full report.

Markets and Reliability Committee

Endorsements (9:10-11:30)

Enhanced Know Your Customer (9:10-9:30)

PJM’s Anita Patel and Eric Scherling will present a proposal to tighten PJM’s know your customer (KYC) rules, which require members to provide information to facilitate the due diligence PJM conducts on key decision-making leadership. The tariff changes would require nonpublicly traded members to provide the names of beneficial owners, board of director members and principals. PJM then would conduct background checks on them. The committee deferred voting on the language during the July MRC meeting to review changes to the definitions of principal and beneficial owners added to the language after its first read. (See “Vote on Enhanced Know Your Customer Deferred,” PJM MRC Briefs: July 24, 2024.)

The committee will be asked to endorse the proposed solution and tariff revisions.

Issue Tracking: Enhanced Know Your Customer

Re-evaluation of Financial Parameters Used in CONE for 2027/28 BRA (9:30-9:50)

PJM’s Skyler Marzewski will present a proposal to recalculate the after-tax weighted average cost of capital (ATWACC) and bonus depreciation values for the 2027/28 Base Residual Auction (BRA). Both of the values are used in the calculation of the cost of new entry (CONE) and have been the topic of discussion as some stakeholders argue that changing market conditions, interest rates in particular, have substantially changed the financing of new generation. (See “PJM Proposes Increased CONE Parameters,” PJM MRC Briefs: July 24, 2024.)

The committee will be asked to endorse the proposed solution and corresponding revisions to the tariff and Manual 18. Same-day endorsement may be sought at the MC.

Issue Tracking: Financial Assumptions Used to Calculate Gross CONE

Automating Bid Duration for Economic DR Participating in Energy Markets (9:50-10:10)

PJM’s Pete Langbein is set to present a proposal to create two new energy market parameters for demand response (DR) resources: a minimum down time and minimum release time.

The committee will be asked to endorse the proposed solution and corresponding Manual 11 revisions.

Issue Tracking: Automating Bid Duration for Economic Demand Response Participating in Energy Markets

Evaluation of Energy Efficiency Resources (10:10-11:30)

Langbein will present a proposal to revise how PJM measures and verifies the capacity offered by energy efficiency (EE) resources. The changes would require EE providers to demonstrate a causal link between capacity market revenues and the viability of their projects, obtain exclusive rights to offer energy savings associated with a project as capacity and reduce the period for which installations can be offered as capacity from four years to one. (See Stakeholders Endorse PJM EE Measurement and Verification Proposal.)

The committee will be asked to endorse the proposed solution. Same-day endorsement may be sought at the Members Committee.

Issue Tracking: Evaluation of Energy Efficiency Resources

Members Committee

Consent Agenda (4:05-4:10)

B. Endorse proposed tariff and Operating Agreement (OA) revisions addressing the performance impact of the multi-schedule model on the Market Clearing Engine. The proposal would use a formula to select one schedule for each generator to be modeled in the real-time market in an effort to prevent multi-schedule modeling from leading to an untenable increase in MCE computation times. (See “Schedule Selection Formula Endorsed,” PJM MRC Briefs: July 24, 2024.)

Issue Tracking: Performance Impact of multi-schedule model in Market Clearing Engine (MCE) in nGEM Enhanced Combined Cycle (ECC) and Energy Storage Resource (ESR) models

C. Endorse proposed tariff and OA revisions intended to resolve delays in how reserve resources are deployed. The changes would transmit deployment instructions through resources’ basepoints, in addition to the existing automatic spin event and all-call notifications, as well as empowering operators to dispatch reserves at a percentage of their maximum commitment. (See “Stakeholders Endorse Reserve Rework, Reject Procurement Flexibility,” PJM MRC Briefs: July 24, 2024.)

Endorsements (4:10-4:40)

Enhanced Know Your Customer (KYC) (4:10-4:20)

Patel and Scherling will review the proposed KYC tariff revisions.

The committee will be asked to endorse the proposed solution and corresponding tariff revisions.

Re-evaluation of Financial Parameters Used in CONE for 2027/28 BRA (4:20-4:30)

Marzewski will review the proposed changes to the financial parameters underlying the gross CONE value in the most recent quadrennial review.

The committee will be asked to endorse the proposed solution and corresponding tariff revisions.

Evaluation of Energy Efficiency Resources (4:30-4:40)

Langbein will review the proposed changes to energy efficiency measurement and verification.

The committee will be asked to endorse the proposed solution and corresponding governing document revisions.

August 18, 2024August 20, 2024

FERC OKs $116M Settlement for New Orleans over Grand Gulf Nuclear Mismanagement

FERC sanctioned a partial settlement to resolve many of the New Orleans City Council’s longstanding complaints over management of the Grand Gulf Nuclear Station.

The commission in an Aug. 14 order said Grand Gulf operator and Entergy subsidiary System Energy Resources, Inc.’s (SERI) $116 million partial offer seemed fair and in the public interest (ER18-1182-008).

The settlement resolves numerous grievances New Orleans officials made in 20 FERC dockets related to subpar Grand Gulf operations, ratemaking and tax violations that shifted costs to customers, an unreasonable capital structure and return on equity and excessive costs of the Grand Gulf sale-leaseback renewal. The earliest docket involved in the settlement stretches back to 2017.

The New Orleans City Council settled with Entergy unofficially last spring in a three-part agreement: $116 million to settle allegations around misconduct within SERI; $138 million more to resolve allegations of dubious tax accounting; and lastly, $500,000 to put concerns over reliability to bed. (See Entergy Earnings Call Focuses on La. Resilience Plan, Nuclear Outage and Settlements.)

The partial settlement provides a return on equity moratorium: SERI will use a fixed, 9.65% ROE in monthly sales to Entergy New Orleans that began in June and will continue through June 30, 2026. The agreement also stipulates SERI’s equity ratio in its capital structure won’t exceed 52% in bills to Entergy New Orleans.

Entergy’s operating companies in Arkansas, Mississippi, Louisiana and New Orleans purchase Grand Gulf’s power through SERI. The state public service commissions from the trio of states all have or are on the verge of agreeing to their own settlements with SERI over mismanagement of the southwest Mississippi nuclear plant, with Louisiana the latest to agree to an offer. (See Entergy Touts Louisiana Settlements, Beryl Response in Q2 Earnings.)

August 18, 2024

New York Orders Utilities to Join in Proactive Grid Planning

New York is ordering electric utilities to plan for expected future demand from the clean energy transition and identify urgent infrastructure needs that already exist.

The Public Service Commission on Aug. 15 ordered “proactive planning for upgraded electric grid infrastructure” (Case 24-E-0364) with hopes of meeting the increasing loads created by electrified buildings and battery-powered transportation.

New York and its electric utilities have anticipated and planned for much higher electric use for most of a decade. But it often has been a top-down process that can move much more slowly than load grows. So, a bottom-up approach that is more granular — and hopefully much faster — is being added.

The state’s six major investor-owned electric utilities are directed to collaborate to develop two filings: a proposal for proactively planning to meet the future needs of transportation and building electrification and a proposal identifying urgent needs that may need to be met before the process detailed in the first proposal can be put into motion.

Heat pumps and electric vehicle chargers can be ordered and installed in a matter of weeks or months, but an upgrade to the utility infrastructure supporting them can take more than seven years to move from concept to completion.

The order seeks to narrow this gap, and also to create a unified planning process across the utilities to reduce the chance of infrastructure upgrades being redundant, insufficient or misaligned across utility territories.

This new bottom-up process is intended to complement the Coordinated Grid Planning Process (CGPP) created in August 2023 (Case 20-E-0197), which involves the same utilities but is more suited to a top-down focus on high-voltage transmission, the order explains.

The utilities are directed to recommend whether this new proactive process can formally integrate with the CGPP and, if so, how.

When Schuyler Matteson, clean energy planning lead at the Department of Public Service, completed his presentation on the proposed order, PSC Chairperson Rory Christian said, “I want to clarify something in case some are left with the impression we just figured this out. We did not. In fact, this particular proceeding has been quite some time in development.”

Some of the PSC cases on which this new process is built date back almost a decade, Christian added. “We’ve known this problem was coming.”

Commissioner John Maggiore asked, “Why haven’t we done this already?”

Matteson explained how it took so long, rather than why: Some groundwork already was in place, but the PSC’s July 2020 electric vehicle make-ready order really began the process by which staff “identified some significant differences between planning for transportation loads versus traditional electric system planning and how there was some conflicts there in the ways the loads show up and how to plan for those loads.”

Commissioner Uchenna Bright asked if the rate of electrification of buildings and vehicles had accelerated and if the state is trying to be more strategic about infrastructure investments in response.

“I think that’s exactly right,” Matteson said. “We had fairly stable both peak and average load growth over the last five or 10 years. But as we see fleets responding to both our policies and national policies, we see large, very chunky popcorn-type loads popping up around the state that might be 5, 10, 20 megawatts at a time, which is a very significantly sized load.” Sales of individual electric vehicles and heat pumps add to the load, he said.

Commissioner Denise Sheehan said she thought coordinating the new proactive process with the existing CGPP would be essential. She asked about the economic development potential.

“I would say there’s a couple of ways it’s implicated,” Matteson replied, noting the number and variety of new load requests coming in and the different approaches to meeting them.

“So, a lot of the largest types of loads, the 50-, 100-MW-plus loads that might be coming into the system, they’re likely to be captured under the Coordinated Grid Planning Process, because they often have transmission-level interconnections,” he said.

“But to the extent that we do see significant adoption of new loads coming on of the system on the distribution network, those will have to be incorporated into the distribution scale load forecast that the utilities will use to identify these infrastructure planning upgrades.”

Commissioner Radina Valova said her main concern in considering the draft order had been whether the loads utilities projected actually would materialize.

“Will the commission have the opportunity to review the utilities’ proposed forecasting methodologies,” she asked, “including their underlying inputs and assumptions, the methodologies that they will use specific to the proactive planning process?”

Matteson replied that it’s important to fill the gap “that we think exists right now in terms of really granular, longer-term forecasting for EVs and building electrification.”

As part of the filing that’s requested, 120 days from now, utilities will propose “those different load forecasts, those planning methodologies.” That allows time to evaluate utility proposals, and in “the actual development process of the planning framework, we expect to have some more back-and-forth with the utilities on specifically what data sets are most relevant here.”

Commissioner David Valesky also asked about the commission’s role going forward.

The PSC will be involved repeatedly and soon, Matteson said.

“We heard about a couple of [urgent projects] through our stakeholder process and through the technical conferences where National Grid and Con Edison have already identified projects that may need to enter construction within the next year or so, so those urgently needed projects would come within about 90 days, and then we’d be able to evaluate the need to fund those projects,” he said.

The commission approved the order with a 6-0 vote.

August 18, 2024

NEPOOL Reliability/Transmission Committee Briefs: Aug. 13-14, 2024

Regional Network Service Rate Increase

New England transmission owners have presented a regional network service (RNS) rate increase to $185 per kW-year for 2025, an increase over the $154 per kW-year rate in 2024.

The increase was explained by Jim Augelli of the Participating Transmission Owners Administrative Committee at a joint meeting of the NEPOOL Reliability and Transmission Committees (RC and TC) on Aug. 13. The rate stems largely from incremental revenue requirements and a true-up to account for under-collection in 2024, Augelli said.

David Burnham of Eversource Energy presented the RNS rate forecast for 2026/29, estimating the rate will increase from $185 per kW-year in 2025 to $217 per kW-year in 2029.

Asset condition projects are projected to account for nearly half of forecasted regional investments in 2024 at $814 million and are projected to increase to $965 million in 2025. Regional system plan projects are projected to cost $622 million in 2024 and $254 million in 2025.

Regional Energy Shortfall Threshold

On Aug. 14, ISO-NE provided an update on its work to develop a regional energy shortfall threshold (REST), which is intended to determine an acceptable level of load shed risk during extreme weather events, serving as a complement to the traditional one-day-in-10-years standard. (See ISO-NE Provides Update on Potential New Resource Adequacy Metric.)

The effort to improve upon traditional approaches based on one-in-10 loss of load expectations is part of a broader trend toward more advanced methods of evaluating shortfall risk.

In July, a working group convened by NERC and the National Academy of Engineering issued a report recommending NERC develop a “multi-metric approach” to supplement traditional loss-of-load expectation with expected unserved energy and loss-of-load hours, with a long-term eye at developing additional metrics.

“LOLE does not adequately account for the growing risk, over all hours, arising from increased variability and uncertainty caused by the evolving resource mix and increasing demand levels,” the report stated. (See Report Says New Energy Metrics Needed.)

Jinye Zhao of ISO-NE said the RTO still is assessing which extreme weather events should be used to evaluate shortfall risks.

Zhao said ISO-NE is ranking “all possible 21-day events based on average system risk” to identify those with the highest risk and will further evaluate event candidates by considering key system factors such as fuel inventories, prices and generator outages.

Mike Knowland of ISO-NE said there have been “no notable changes in ISO’s current thinking with regard to REST periodicity or REST metrics and thresholds” since the RTO’s update in May.

Votes

The RC voted to support conforming changes to ISO-NE planning procedure 5-6 associated with Order 2023 and Order 2023-A compliance.

Alex Rost of ISO-NE said additional changes may be needed to the planning procedures after the start of the transitional cluster study but prior to the start of the first cluster study.

The RC also voted to support revisions to Operating Procedure (OP) 12, which relates to voltage and reactive control. The revisions stemmed from the periodic review process and would affect voltage control options and voltage scheduling.

The committee also supported changes to OP-23 related to generator form submission rules for resource auditing.

August 18, 2024

Some MISO Regulators Signal Early Discontent with New MISO-PJM Interregional Study

Some members of the Organization of MISO States are implying that MISO’s new interregional study with PJM is falling short of their hopes for a rigorous search for seams transmission projects.

At an Aug. 14 MISO Advisory Committee meeting, OMS Executive Director Tricia DeBleeckere said OMS is exploring next steps regarding whether the requests contained in its joint letter with the Organization of PJM States Inc. (OPSI) line up with the aims of MISO and PJM’s new transfer capability study. She also said OMS wants more visibility from MISO into the inaugural study.

OMS and MISO will continue to meet to discuss the scope of the study, regulatory staff said at an Aug. 15 OMS Board of Directors meeting.

MISO and PJM have said they will pursue only smaller, near-term projects at the seams for the inaugural study, not the more complex, interregional construction that requires greenfield development. (See Smaller Projects Expected from Maiden MISO-PJM Joint Tx Study.)

At a late July OMS meeting, Michigan Public Service Commission Chairman Dan Scripps said representatives from the Organization of MISO States approached officials about the limits of the study scope.

Scripps said while MISO may envision potential projects as a simple reconductoring of lines, that’s not exactly what OMS and the OPSI meant when they requested more meaningful interregional planning.

“I think there are some additional conversations needed, and I hope we can go further than what’s been put on the table,” Scripps said.

At the time, Scripps said regulators would meet with MISO planners again on “whether this hits the mark.”

“We kind of got cut out of the conversation on the scoping of this study,” Wisconsin Public Service Commissioner Marcus Hawkins said.

Responding to regulators’ observations, MISO Vice President of System Planning Aubrey Johnson said MISO and PJM “have a long history of working together to address operational and planning challenges in our regions.”

“We will continue working with our regulators and other grid operators to explore interregional planning solutions with a focus on both addressing near-term needs and building a framework for future studies,” Johnson said in a statement to RTO Insider.

At the August Advisory Committee, MISO members said OMS and OPSI’s letter urging more dynamic joint planning should be featured during Board Week meeting Sept. 18, where RTO members and board members are set to hold a discussion titled “Seams: Reliability and Market Efficiency Across Borders.”

WEC Energy Group’s Chris Plante said MISO and PJM also should consider improving coordination on larger projects that are near the seams but aren’t interregional projects. He cited ComEd’s expansion of its 765-kV Wilton Center substation to accommodate more renewable energy and its potential impact on the RTO’s footprint.

August 15, 2024August 15, 2024

NERC Board of Trustees/MRC Briefs: Aug. 15, 2024

Board Invokes Standards Authority to Meet IBR Deadline

VANCOUVER, British Columbia — NERC’s Member Representatives Committee and Board of Trustees met Aug. 15 for their final in-person gatherings of the year.

With a FERC-imposed deadline rapidly approaching for the submission of reliability standards governing ride-through performance of inverter-based resources, the board for the first time invoked its authority to streamline the ERO’s stakeholder approval process.

FERC ordered NERC in October 2023 to submit reliability standards addressing IBR performance requirements and IBR disturbance monitoring data sharing and post-event performance validation by Nov. 4, 2024. (See FERC Orders Reliability Rules for Inverter-Based Resources.) NERC assigned the development work to three ongoing standards development projects, which produced five draft standards:

- PRC-028-1 — Disturbance monitoring and reporting requirements for inverter-based resources;
- PRC-002-5 — Disturbance monitoring and reporting requirements;
- PRC-029-1 — Frequency and voltage ride-through requirements for inverter-based resources;
- PRC-024-4 — Frequency and voltage protection settings for synchronous generators, Type 1 and Type 2 wind resources, and synchronous condensers; and
- PRC-030-1 — Unexpected inverter-based resource event mitigation.

Four of the proposed standards have met the two-thirds weighted stakeholder approval needed for submission to FERC, but at the time of the board meeting, PRC-029-1 had again failed to receive approval in its most recent formal ballot round that ended Aug. 12. With the deadline less than three months away, board Chair Kenneth DeFontes said “it’s not clear NERC’s usual process can produce a consensus standard.”

“NERC has a regulatory responsibility to file reliability standards addressing [FERC’s order] by Nov. 4, but equally important is [that] it’s the right and necessary thing to do,” DeFontes said. “The board needs to consider taking special action to get [the] IBR ride-through standard done on time.”

The resolution was recommended to the board by the Regulatory Oversight Committee (ROC) in its meeting Aug. 14. Using the board’s authority under Section 321 of NERC’s Rules of Procedure, it directed the Standards Committee to convene a technical conference Sept. 4-5 in the ERO’s D.C. office.

NERC will use input from the technical conference to revise the proposed standard, which will be submitted for stakeholder ballot. If it receives a two-thirds weighted stakeholder approval, the standard will be considered approved; the board still may consider adopting the standard if it receives at least 60%, though an additional comment period and technical conference may be needed.

“Over the years, the board has seen industry rise to the occasion time and time again to address tough issues and FERC directives through NERC’s standard development process,” DeFontes said. “We’ve said before that stakeholder input is essential to the success of the ERO model, and that remains true. The ROC’s recommendation … is to focus our stakeholder efforts for one final push [toward] developing a consensus standard. … I encourage our drafting teams and stakeholders to continue to participate and bring their knowledge and unique perspectives to this process.”

Budgets Headed to FERC

Additional actions at this week’s meetings include the acceptance of NERC’s 2025 Business Plan and Budget, along with those of the regional entities and the Western Interconnection Regional Advisory Body. The budgets will be submitted to FERC for approval.

The final business plans and budgets are “materially consistent” with NERC’s three-year projection, CFO Andy Sharp told the Finance and Audit Committee at its open meeting Aug. 14. NERC, the REs and WIRAB will see their combined budgets increase 9.1% over their 2024 levels to $304.6 million, while the collective assessment will grow 12.2% to $270.9 million; NERC’s budget alone is set to grow to $123 million, up 8.2% over 2024, while the assessment will rise 11.8% to $108.4 million.

MRC Elections to Begin in December

Nominations for the MRC’s officers will open Sept. 18 and close Oct. 17, Chair Jennifer Flandermeyer said during the committee’s meeting. Officers will be elected by current members Nov. 13 at the MRC’s final meeting of the year, which will be held in a hybrid format with only members attending in person.

Meanwhile, nominations to replace members whose terms expire next February will open Sept. 4 and close Dec. 1. The election will run Dec. 2 to 11.

Trustee Larry Irving, chair of the board’s Nominating Committee, also shared an update on the search for a trustee to succeed Bob Clarke, who will leave the board at the expiration of his term in February 2025. Clarke has served on the board since 2013, making him ineligible for renomination.

Irving reported that the Nominating Committee has selected a search firm to assist with the recruitment and “reviewed an initial pool of candidates” that he called “outstanding.” He said the committee plans to recommend a candidate to the MRC in December, with the election to take place next February.

August 15, 2024August 19, 2024

SPP Dispels Concerns over Markets+ Deficiency Letter

WESTMINSTER, Colo. — Meeting with potential Markets+ participants for the first time since FERC filed a deficiency letter over SPP’s tariff filing for the proposed day-ahead market, the grid operator’s staff assured the Markets+ Participant Executive Committee that recent developments have not hindered the RTO’s commitment to Western expansion.

“So far as we’re concerned, nothing’s changed,” Carrie Simpson, SPP’s senior director of seams and Western services, told RTO Insider following the MPEC’s Aug. 13 meeting. “We’re creating what we think is a great product for the West and the best product for the West. We will determine over the next several months who participates, but right now, our focus is the tariff approval.”

FERC issued the deficiency letter July 31, directing SPP to respond to a list of 16 questions related to the tariff. It gave the RTO until Sept. 30 to respond. (See FERC Finds SPP Markets+ Tariff ‘Deficient’ in Several Areas.)

SPP’s legal staff pointed out that the commission’s letter is not a rejection or a likelihood of future rejection, but a “routine process” that SPP has participated in over the years.

“None of the questions indicate to me there’s a serious risk to Markets+,” General Counsel Paul Suskie told the committee. “They indicate to me that FERC is just trying to get additional information.”

Suskie said FERC has sent SPP 41 deficiency letters since 2010. The vast majority (32, or 78.05%) were resolved with SPP’s first response. Of those tariff revisions that SPP refiled, all were approved — including its tariff for the Western Energy Imbalance Services market, in operation since 2021 — except one that is still pending, he said. (See FERC Approves SPP’s Western Market Tariff.)

“I’ve responded to my share of those 41 deficiency letters. This deficiency letter reads to me like FERC wants education. They’ve asked for an explanation,” staff attorney Christopher Nolen said. “Of course, I would prefer the order, but as deficiency letters go, I’m good with this one.”

Nolen said most of the commission’s questions dealt largely with transmission. He noted there were no questions on governance, seams or market fundamentals, saying, “To me, that’s at least as important as the questions they asked.

“I can’t stress enough that they seem to be especially interested in education on how transmission will work in Markets+. If you step back and think about Markets+, how it’s designed and how it works, that’s perfectly reasonable,” Nolen said. “It’s a number of others, a number of parties, a number of balancing authorities, all bringing transmission together for us to effectuate a day-ahead, first-in-class market.”

Staff said they are working quickly to meet the deadline, using examples from stakeholders to respond to the questions. The effort is not expected to delay the 2027 target go-live date or the overall timetable, as SPP has built in additional time to the schedule to serve as a buffer.

“When I ran through these questions on my first pass-through, I thought, ‘Wow, these are all answerable questions.’ So, we have an idea how to answer all these questions,” Nolen said. “I don’t think it will take 60 days.”

SPP said CEO Barbara Sugg’s pending retirement will do nothing to slow its Western expansion, in which the Markets+ service offering will play a large role.

“Our commitment to the West is the strongest it has ever been,” said Antoine Lucas, vice president of markets, stressing that Markets+’s role in the strategy is “unchanged” by Sugg’s decision.

Director Steve Wright said Sugg has done an “outstanding” job and is “extremely committed” to both the RTO and its Western expansion efforts.

“Having said that, there are nine other board members who have been very actively engaged in this process,” he said. “The [board’s] other members have been very interested in this activity as well and have been kept fully briefed as we move along and understand the status of this project, and have been very supportive of it.”

In the meantime, potential Markets+ participants are working on the protocols that will set the market’s mechanics. Three different working groups presented their first batch of protocols for consideration. All were approved unanimously.

The MPEC also approved two chairs to fill vacancies in the stakeholder groups. Puget Sound Energy’s Jessica Zahnow will lead the Markets+ Interim Governance Task Force, and Bonneville Power Administration’s Libby Kirby will chair the Markets+ Operations and Reliability Working Group.

Staff told stakeholders they have board approval to engage with lenders over Markets+’s second-phase funding agreements that will be extended to participants by year-end. SPP expects its administrative costs to run between $65 million and $70 million annually.

Until then, SPP can only wait on FERC’s response to the RTO’s response.

“We anticipate more certainty at that point related to FERC,” Simpson said. “That’ll be the time period when I think parties will decide what they plan to do. We just want them to have choices, at that point.”