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November 14, 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.

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)

  1. 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 

  1. 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 

  1. 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 

  1. 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)

  1. 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. 

  1. 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. 

  1. 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. 

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.)

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. 

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.

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.  

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 Chair Kenneth DeFontes (left) talks with CEO Jim Robb before the board meeting. | © RTO Insider LLC

“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. 

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.)

Chris Nolen, SPP | © RTO Insider LLC

“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.”

The MPEC reviews protocols for approval brought by the Markets+ Market Design Working Group. | © RTO Insider LLC

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.”

The IRA at 2: A Mixed Record of Achievement and Uncertainty

Money from President Biden’s two signature climate laws isn’t just being used for big clean energy projects to produce zero-carbon hydrogen and suck carbon dioxide out of the air, according to a Department of Energy official.

The Infrastructure Investment and Jobs Act and Inflation Reduction Act are “delivering clean energy upgrades to school children in Selma, Alabama,” for example, and “decarbonizing food production in America’s heartland, one mac and cheese at a time,” said Doug Schultz, chief operating officer at the DOE’s Office of Clean Energy Demonstrations (OCED).

During DOE’s Aug. 14 webinar marking the second anniversary of the IRA, Schultz described how the OCED awarded the Kraft Heinz Co. up to $170.9 million earlier this year to “upgrade, electrify and decarbonize food production” at 10 of its plants, including a Michigan factory producing Kraft’s signature comfort food, Schultz said.

“It takes a whole lot of heat to dry all that macaroni, which produces a whole lot of emissions,” he said. “This project will employ clean tech like heat pumps, electric heaters and electric boilers to slash those emissions 99%.”

Biden signed the IRA into law Aug. 16, 2022. It is the largest federal investment in climate and clean energy action in U.S. history, and in the weeks leading up to the IRA’s second anniversary, DOE and other agencies have been heralding the law’s impact and benefits for Americans across the country.

In opening remarks at the webinar, Kathleen Hogan, principal deputy under secretary for infrastructure, reeled off numbers from DOE’s recent Progress Update, tracking the department’s implementation of IRA and IIJA programs. All of the new programs established in the two laws have been launched, and $48.7 billion has been awarded to thousands of projects, Hogan said.

A DOE video highlighted a new factory in Weirton, W.Va. ― a former steel town ― where startup Form Energy is using IRA tax credits to help it build long-duration iron-air batteries, while paying workers average wages of more than $63,000, according to Ted Wiley, president and chief operating officer.

Figures released by the Treasury Department on Aug. 7 showed that “more than 3.4 million American families had already claimed more than $8 billion in residential clean energy and home energy efficiency tax credits against their 2023 federal income taxes.” The lion’s share ― $6 billion ― went to the 1.2 million households that installed solar panels and batteries and received tax credits averaging $5,000 per family.

A General Services Administration press release announced the agency so far has spent $480 million out of its $3.4 billion in IRA funds for “sustainable improvements to federal buildings across the country” and also has promoted the use of low-carbon building materials on those projects.

But the achievements come after an occasionally rocky two years in which IRA implementation has progressed in fits and starts.

Pain points include the Treasury Department’s still-incomplete efforts to provide guidelines for all of the law’s tax credits, with some companies and their investors waiting on the sidelines because of uncertainty about whether their projects will be able to benefit.

The tax credit for clean hydrogen is a prime example. Treasury released proposed guidelines in December 2023 but has yet to finalize the rules, which will be critical for the development of the seven hydrogen hubs OCED announced last October. They’re intended to build out a clean hydrogen industry. But only three of the hubs have signed contracts with DOE, allowing them to begin planning the projects.

Similarly frustrating, the IRA’s programs providing rebates to help low-income families install energy-efficient appliances — like heat pumps — have rolled out at a glacial pace. Wisconsin and New York are the only states so far that have launched programs.

According to Ward Lenz, deputy director at DOE’s Office of State and Community Energy Programs, 22 states have submitted applications, and he expects more to come in. However, some states are very early in the process. For example, the Maryland Energy Administration (MEA) announced in July that DOE had approved its application to receive “early administrative funds” provided by the law, so it could start planning its program.

The money will be used to hire staff to design and implement the program, MEA said. While acknowledging the high level of public interest in the rebates, the agency has yet to announce any target dates for when the federal dollars might be available.

‘Overly Rosy’ Expectations

The IRA’s impact on clean energy manufacturing has been one of the law’s most widely hailed achievements, with a recent report from the American Clean Power Association noting the law has stimulated $500 billion in private investment in new plants and projects. Of the more than 160 projects announced in the past two years, 42 are online or under construction, the report says.

DOE’s Grid Deployment Office also has been active in awarding IRA funds to expand grid capacity across the country, with its Grid Resilience and Innovation Partnership (GRIP) awards. Most recently, $2.2 billion in GRIP awards were announced for eight projects, including two interregional lines and six that will increase capacity on existing lines with grid-enhancing technologies. (See DOE Announces $2.2B in Grid Resilience, Innovation Awards.)

Such encouraging numbers don’t always align with public perceptions. A poll conducted by the University of Chicago’s National Opinion Research Center in April asked a series of questions about the IRA, and in almost all cases more than a third of participants said they didn’t know enough about the law to answer.

Further, only 15% to 26% of participants saw the IRA as providing benefits to people like themselves, depending on particular provisions of the law, such as tax credits for electric vehicles or rooftop solar or grants for clean energy projects in low-income communities.

Amy Turner, director of the Cities Climate Law Initiative at Columbia University’s Sabin Center for Climate Change Law, said such polls may not capture a longer view of the law.

“The IRA has programs that are meant to last as long as a decade,” Turner said in a phone interview with NetZero Insider. “Just because we have an anniversary of the law doesn’t necessarily mean that this is the anniversary when everything is meant to be happening all at once, at the same time.”

The billions of dollars in the law have posed a heavy lift for DOE and other agencies, which “have been standing up really massive new programs that are now operational and getting money out the door,” she said. “They weren’t necessarily experienced in the things that they were being asked to do.”

In some cases, like the home energy rebates, expectations of how quickly the money would be available were “overly rosy,” Turner said. “[The] dates that we can expect to see the rebates active in different states across the country have been continually kind of pushed back,” as individual states develop plans that must be approved by DOE.

Turner said she believes the IRA’s provisions that allow for direct pay of its tax credits may have the longest lasting and transformative impacts. “This is a 10-year program,” she said. “It really stands to change the way that states, tribes, local, nonprofits and a range of other non-taxpayers pay for things like renewable energy development and clean vehicles.”

Those entities previously had been unable to take advantage of clean energy tax credits because they don’t file taxes and therefore had no way to use the credits. With limited options, they often had to work with third-party developers who could use the credits.

The direct pay provisions allow them to get the credits as a cash payment but do require them to file complicated paperwork with the Internal Revenue Service, which is slowing uptake, Turner said. Officials in small towns and nonprofit staff members have to learn in real time, she said.

“So, the hope is that by a handful of non-taxpayers going first and figuring out some of these early hurdles, the broader public can learn how to proceed, and the IRS can smooth out some of its processes,” Turner said.

Turner also said the IRA’s direct pay provisions should be unaffected by election results. “Even after all [the law’s] grant money is allocated and goes out the door, this is a program that remains in the tax code until 2032. A president cannot change it on his or her own. It would require Congress to act,” she said.

Revolution, Sunrise OSW Projects Face New Delays

Ørsted has run into new delays that will push back completion of at least one of the two offshore wind farms it’s building in U.S. waters. 

The world’s largest offshore wind developer said Aug. 15 that complications with the onshore substation for its Revolution Wind will push completion of the project from 2025 to 2026, and the complexity of building the first offshore HVDC system in the United States may push completion of Sunrise Wind from late 2026 to the first half of 2027. 

As it released its first-half 2024 financial report, the company said it will record new impairments due to the Revolution Wind delay and its decision to suspend FlagshipONE, the e-methanol ship fuel production facility it was building in Sweden. Its stock price closed 7.2% lower. 

The announcement was the latest setback for Ørsted in its U.S. offshore wind development portfolio. It booked billions in impairments in 2023 as it canceled Ocean Wind in New Jersey, canceled the offtake contract in Maryland for Skipjack Wind and declared that Sunrise Wind was untenable under terms of its contract with New York. (See Ørsted Cancels Ocean Wind, Suspends Skipjack, Ørsted Cancels Skipjack Wind Agreement with Maryland, NY Rejects Inflation Adjustment for Renewable Projects.) 

Amid all that, Ørsted and its partner Eversource decided in October to move forward with Revolution Wind, a 704-MW wind farm that will feed into the grid in Connecticut and Rhode Island, having determined they could work around supply chain constraints and vessel availability issues that slowed or halted other Northeast projects. 

And in fact, Ørsted CEO Mads Nipper said Aug. 15, offshore construction of Revolution is going well — 44 of 67 foundations are in place and turbine installation will start in the coming weeks. 

The chokepoint now is onshore — a toxic legacy of the past rather than growing pains for the clean energy of the future. 

The substation is to be built on a former U.S. Navy disposal site in Quonset Point, R.I., that turns out to be more heavily contaminated than previously thought. The mitigation requirements therefore are greater than initially projected. 

The situation is unsatisfactory but will not deter Ørsted from its long-term goals, Nipper said. 

Eversource, which also has incurred heavy losses in the offshore wind space, has sold its 50% share of Sunrise to Ørsted and is selling its 50% share of Revolution to GIP. (See Eversource Finds OSW Buyer, Takes $1.95B Hit for 2023.) But it will remain involved with the onshore portions of the projects, including the Revolution substation. 

Meanwhile, the financially untenable Sunrise contract has been replaced with a deal with New York state that carries much higher compensation to reflect the sharply higher costs of building the 924-MW offshore wind farm. (See Sunrise Wind, Empire Wind Tapped for New OSW Contracts.) 

When federal regulators approved the construction and operations plan for Sunrise on June 21, Ørsted said it would start offshore construction this year and that it expected to be done in 2026. (See Sunrise Wind Cleared to Begin Construction.) Onshore construction has been under way for months and officially broke ground in July. 

On Aug. 15, Ørsted said it would start offshore installation in 2025 and that the commissioning date could slip from the end of 2026 into the first half of 2027, due to the pioneering nature of its use of HVDC cable. 

Ørsted reported an impairment equal to $310 million on the Revolution delay but said the potential Sunrise delay is incorporated into planning and would not result in an impairment. In fact, Ørsted reversed $256 million of previous impairments due to Sunrise securing the new contract with New York. 

In a conference call Aug. 15 with financial analysts, Nipper said, “In the offshore business, no project is without challenges and risk. There is no reason with the current knowledge to believe that what we have now is not realistic. It would be speculation to say, ‘What else could go wrong?’ because what we present to you now is a plan that we believe in.” 

He also gave an update on other aspects of Ørsted’s offshore wind business: 

    • It took an $88 million impairment on the diminished value of the seabed lease areas off the New Jersey coast it once targeted for Ocean Wind. 
    • Repurposing the export cable that would have been installed at Ocean Wind for the Hornsea project off the English coast would be financially beneficial, and Ørsted is progressing with plans to do so. 
    • The company has no plans to use Chinese-made wind turbines but does not rule them out; it would consider any product that met specifications and standards. 
    • The Skipjack concept remains in active development — a revised construction and operations plan recently was submitted to federal regulators — but there is no specific plan yet for moving toward construction. 
    • Ørsted has been able to firm up its supply agreements for monopile foundations, one of the more significant pinch points in the supply chain, and it has secured the services of installation vessels, which are in critically short supply. 
    • It has scrutinized other planned substation sites, including for Sunrise, and has not found issues comparable to the problems facing the Revolution site. (Nipper said in November 2023 there was contamination at both the Sunrise and Revolution cable landing sites, enough that both would qualify as brownfields eligible for enhanced investment tax credits.)