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October 3, 2024

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CARB Promises Closer Look at Biomethane Role in LCFS

Prompted by a petition from environmental justice groups, California regulators will take a closer look at the role of dairy-manure biomethane in the state’s low-carbon fuel standard this year.

The petition, submitted in October to the California Air Resources Board, asked CARB to launch a rulemaking to exclude biomethane derived from dairy or swine manure from the agency’s low-carbon fuel standard (LCFS).

The groups contend that the LCFS overstates the climate benefits of using the so-called “factory farm gas” as a transportation fuel. They say the LCFS credit system provides incentives for farm expansion, leading to increased air and water pollution. (See Petition Would Bar ‘Factory Farm Gas’ from CARB LCFS Credits.)

The petitioners include Public Justice, Food and Water Watch, the Animal Legal Defense Fund, the Association of Irritated Residents, Leadership Counsel for Justice and Accountability, and the Vermont Law School Environmental Justice Clinic.

In a response dated Jan. 26, CARB Executive Officer Richard Corey denied the groups’ request to amend LCFS at this time, calling the requests for near-term rulemaking “premature.” Corey noted that CARB will revisit the LCFS in 2023, after completing an update to its climate change scoping plan this year.

But during a CARB board meeting on Jan. 27, Chair Liane Randolph asked CARB staff to hold a public workshop in the next few months specifically on the role of dairy-manure biomethane in the LCFS, to be followed by a report to the board.

Randolph’s request came after several other board members weighed in on the issue.

Board member Tania Pacheco-Werner asked if CARB could conduct a technical review of information on dairy-manure biomethane that has come to light since the LCFS regulation took effect. She said the answers are important as several dairy-digester projects are in the development pipeline.

“Personally, I want to see resolution of this as quickly as possible,” said Pacheco-Werner, who is a governing board member for the San Joaquin Valley Air Pollution Control District.

Carbon-intensity Benchmarks

CARB’s low-carbon fuel standard assigns a carbon intensity score to different transportation fuels. It also sets a carbon-intensity benchmark that fuel providers must meet. Providers that don’t meet the benchmark can make up the difference by buying credits awarded to producers of low-carbon intensity fuels.

Dairy-manure biomethane is a fuel potentially eligible for credits under the LCFS.

The environmental justice groups’ petition alleges that the LCFS credit system doesn’t account for emissions throughout the full life cycle of the biomethane, which is generated from the anaerobic digestion of dairy cows and swine manure.

The petition says the credit system incentivizes expansion of the factory farms, which allegedly has disproportionate environmental and health impacts on low-income communities and communities of color, particularly in the San Joaquin Valley.

The petition asks CARB for a rulemaking to amend the LCFS to exclude all fuels derived from factory farm gas, or to modify LCFS to account for emissions over the entire lifecycle of dairy-manure biomethane.

In his response to the groups’ petition, Corey said CARB’s long-range scoping plan, which takes a big-picture look at greenhouse gas-reduction strategies, may include recommendations regarding the LCFS. CARB expects to finalize the scoping plan update by the end of the year.

Corey said information gathering is another key step before the agency makes changes to the LCFS. He said during the CARB board meeting that some of the issues raised regarding the LCFS are not new, and “I have not seen the evidence of the claims that are being made.”

“If there truly is new data that is contrary to the historical record and the underlying analysis, I’m very interested in seeing that,” Corey said.

Corey and other CARB senior managers met with petitioners before issuing a response, and he said further dialogue is welcome.

Methane-reduction Goal

The debate over dairy-manure biomethane came up during public comments in response to a CARB presentation on 2022 priorities.

Michael Boccadoro, executive director of Dairy Cares, a dairy industry coalition, said the digesters are essential to helping the dairy sector meet California’s goal of reducing methane emissions by 40%.

“Without digesters, there is no way to achieve the 40% goal,” Boccadoro said during the CARB board meeting. “Without markets like the LCFS for utilization of the methane that is captured, these projects are not economic and cannot be financed and implemented.”

Boccadoro previously described dairy digesters as the state’s most cost-effective and successful climate investment.

Other speakers expressed disappointment with Corey’s response to the petition.

“This petition has been brushed aside with empty promises [that] it will be considered in the future,” said Tom Frantz with the Association of Irritated Residents. “In other words, ‘Blah, blah, blah.’”

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ISO-NE’s Plan to Delay MOPR Removal Wins out at NEPOOL

NEPOOL’s senior stakeholder committee Thursday signed off on a plan to delay the elimination of ISO-NE’s minimum offer price rule (MOPR), which the RTO abruptly threw its support behind last week after months of working on a different proposal that would have removed the contentious rule immediately.

The debate over the plan initially put forward by generators Calpine and Dynegy, which ISO-NE can now submit to FERC, is the latest volley in a long-running dispute over the effects of a rapid transition to renewables on the reliability of the region’s grid.

The MOPR sets a price floor for bids into the capacity market, designed to prevent what its backers say are “artificially” low prices caused by the participation of state-supported resources.

ISO-NE said that its backing of the two-year transition away from the MOPR, rather than immediate removal, is designed to slow the entry of state-sponsored resources into the capacity market to a “steady pace” rather than a “sudden, voluminous and permanent shift.” (See In Late Twist, ISO-NE Calls for 2-Year Delay on MOPR Elimination.)

The grid operator has worried that reliability of New England’s grid could suffer from a rapid influx of sponsored resources and an exodus of existing generators.

“What I know, based on what we’ve observed and studied and seen, is that a transition offers the most measured way forward … and gives us much-needed time to put in place critical reforms,” ISO-NE COO Vamsi Chadalavada told stakeholders at the Participants Committee meeting Thursday. “We are convinced of this position and this judgment, and we do need your support, because the best way for us to move forward is collectively, rather than arguing back and forth about what’s right and what’s wrong.”

The transition plan was backed by generation, transmission and supplier sectors in the NEPOOL vote Thursday. It’s also not opposed by five of the six New England states (with New Hampshire as the outlier because the state opposes MOPR removal altogether).

But renewable developers, advocates and environmental groups have cried foul, arguing that the RTO has not made its case convincingly that the transition is necessary for reliability.

“The ISO provided no quantitative support … that deviating from its blueprint established nine months earlier to impose a delay will reduce reliability risks,” the nonprofit RENEW Northeast wrote in a memo this week, also noting that “temporary programs have a habit of being extended.”

“The grid operator’s saying we’re not going to allow new clean energy resources to fairly compete in the region’s market until almost the end of the decade,” Bruce Ho, senior advocate at the Natural Resources Defense Council, said in an interview. “That’s pretty extreme and really doesn’t seem in line with what [FERC] has been pushing for.”

Joe Curtatone, president of the Northeast Clean Energy Council, took to Twitter to slam the MOPR transition proposal.

“Much of what shapes our energy supply and the fate of our climate takes place in meetings few people know about, like at NEPOOL today,” the former Somerville, Mass., mayor wrote. “There’s a rule that forces clean energy to submit higher bids that protect fossil fuel suppliers. It’s grimy insider baseball, and it needs to stop.”

The transition plan does allow for up to 700 MW of capacity from state-subsidized resources to enter the market through a renewable technology resources (RTR) exemption in Forward Capacity Auctions 17 and 18 (300 MW in FCA 17 and 400 MW in FCA 18). And the committee approved an amendment from RENEW Northeast that would carry over any unused megawatts between those two years.

The plan now faces an uncertain future at FERC.

Members of the commission’s Democratic majority, Chairman Richard Glick and Commissioner Allison Clements, wrote recently that the MOPR makes ISO-NE’s tariff unjust and unreasonable, and that the RTO should move forward “expeditiously” with eliminating it. (See FERC Weighs in as ISO-NE Prepares for Capacity Auction.)

A FERC spokesperson said that Glick “does not want to risk prejudging the matter” and will wait for an official filing before the commission to comment on the ISO-NE proposal.

“What ISO-NE is proposing doesn’t seem to align with what commissioners are asking the grid operator to do,” Ho said. “I think we saw very clearly from the chairman … that he expects ISO New England to get rid of the unjust and unreasonable MOPR rule.”

Consent Agenda

The Participants Committee also approved three items on its consent agenda:

  • changes to the resource retirement process to allow retirement bids to be updated later in order to give generators more flexibility, proposed by Calpine and recommended by the Markets Committee last month. (See NEPOOL Markets Committee Briefs: Jan. 12, 2022.)
  • biennial review revisions to ISO-NE Operating Procedure No. 5 (Resource Maintenance and Outage Scheduling) Appendices A (Operable Capacity Calculations) and B (Outage Request Form), as recommended by the Reliability Committee.
  • revisions to Appendix G (Designated Blackstart Resource Commitment) to OP-11 (Blackstart Resource Administration), as recommended by the RC.
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New Jersey Committee Advances $45M Electric Bus Bill

The New Jersey Senate Transportation Committee approved a bill Thursday that would allocate $45 million for a three-year pilot program for electric school buses.

The bill (S759), which advanced with a 6-0 vote and one abstention, would create a program under which six districts or contractors each year would assess the reliability and effectiveness of using electric buses in place of diesel-powered vehicles. At least half of the districts or contractors would be in low-income, urban or environmental justice communities.

During the pilot, the performance of the buses would be evaluated and data on costs, maintenance, fuel and bus speed and movements would be collected and submitted to the New Jersey Department of Environmental Protection.

The bill’s introduction comes amid concerns from environmental groups that the state should move more quickly toward electrification of school and transit buses. As of last October, there were no electric school buses registered in New Jersey, said Atlas Public Policy, a Washington D.C.-based consultant on transportation and building electrification issues.  (See NJ Floats New Electric Bus Plan.)

Three environmental groups spoke in support of the bill, and nobody opposed it.

“Senate Bill 759 will begin the process of replacing diesel school buses,” Anjuli Ramos, New Jersey director at Sierra Club, told the committee. While up-front costs of electric buses are high, she said, clean energy buses can be cheaper in the long run.

“The economic and environmental benefits of using electric school buses far outweigh using diesel buses,” Ramos said.

Project Delay

Converting to electric buses is one piece of the New Jersey effort to get 330,000 electric vehicles on the road by 2025 and reach 100% clean energy by 2050. The state is mid-way through enacting a rule proposal to encourage the creation of charging stations that would service electric buses and medium- and heavy-duty trucks. (See NJ’s EV Charger Rules Face Scrutiny.)

New Jersey has allocated $22 million since 2019 for 18 school districts or bus contractors to help buy 71 electric school buses. Pam Frank, CEO of ChargEVC-NJ, an advocacy group that champions electric vehicle policies, told a senate committee in November that none of the buses are in operation.

The $45 million pilot program bill follows similar legislation introduced in November that secured Senate approval, 35-3, but did not advance in the assembly before the legislative term ended in January. That bill followed legislation that would have allocated $10 million to fund three test projects, which also did not pass.

Doug O’Malley, state director of Environment New Jersey, said he hoped the bill “can move forward quickly in both houses.”

“This pilot program is designed not only to get electric school buses on the road, but be able to figure out what works,” he said.

NJ Transit, the state’s mass transportation agency, said this week that the delivery of eight buses for the pilot in Camden has been delayed by more than six months.

The agency approved a $9.5 million purchase of eight buses in October as part of an effort to convert its fleet of 3,000 buses to zero emission by 2040. The buses will operate out of the Newton Avenue Bus Garage in Camden, which is undergoing a $3 million renovation, including the installation of chargers.

NJ Transit said this week that the agency expected the first of the new buses to arrive by the end of 2021. But they are now scheduled for arrival in June, with the full complement of eight arriving by the end of the year. The agency agreed to the delay during the solicitation phase, at the request of vendors who sought more time to prepare, a spokesperson told NetZero Insider.

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Report Warns of Growing Cyber Dangers

A handful of high-profile cyberattacks grabbed headlines last year, but cybersecurity advisory firm Tenable said in a report this week that the biggest challenge for the security community continues to be “age-old security challenges in new infrastructure.”

“Organizations continue to struggle with protecting, or even defining, the perimeter. Migration to cloud platforms, reliance on managed service providers, software and infrastructure as a service have all changed how organizations must think about and secure the perimeter,” the 2021 Threat Landscape Retrospective said. “Fragmented security solutions and poorly defined security outcomes must be left behind to match the complexity of the modern attack surface.”

Tenable’s goal was to highlight the security issues that plagued the public and private sector last year. While big events drew most of the public’s attention last year — for example, the compromise of the SolarWinds Orion network management software that began in December 2020, and the ransomware attack against Colonial Pipeline in May — the firm said these hacks were the tip of the iceberg, with 1,825 total breach events detected from Nov. 1, 2020 to Oct. 31, 2021.

OT, IT in ‘Attackers’ Crosshairs’

While details on many of last year’s cyber incidents have not been disclosed due to security and privacy concerns, or the desire of companies involved to avoid embarrassment, Tenable’s analysis shows more than 260 terabytes of data was stolen comprising 1.8 billion files, documents or emails.

About 38% of all breaches that Tenable analyzed were the result of ransomware attacks, such as the one against Colonial that led to the shutdown of the company’s entire pipeline network and stifled the flow of petroleum products to the U.S. East Coast. (See Colonial CEO Welcomes Federal Cyber Assistance.) Meat supplier JBS suffered a similar ransomware attack; like Colonial, its leadership decided to pay the attackers to unlock their computer systems and prevent the release of sensitive data. The two companies’ ransoms amounted to the equivalent of around $16 million.

While the Colonial and JBS breaches garnered national attention and concern at the highest levels of government, the energy, infrastructure and utilities sectors accounted for only a small fraction of ransomware attacks and total breaches. As in 2020, Tenable found that attacks fell most heavily on the healthcare sector, which accounted for nearly a quarter of the year’s total events, followed by education, with 13%.

However, the firm warned that utilities and other critical infrastructure operators should not rest easy, since last year’s incidents “proved that information technology (IT) and OT [operational technology] environments are in attackers’ crosshairs,” along with critical infrastructure. And since many of the same software tools are used across multiple industries, successfully breaking into one common platform can render all its users vulnerable.

This is what happened with the SolarWinds hack, in which the breach of the Orion software — now attributed to Russia’s Foreign Intelligence Service — may have exposed the information of thousands of customers, including the Department of Energy and FERC. (See FERC, E-ISAC Report Details Reach of SolarWinds Compromise.) The same hackers have since been blamed for additional attacks, including breaches of Microsoft and computer services provider Pulse Connect Secure.

Zero-days Across Common Software

A common point of entry for hackers are zero-day vulnerabilities, defined by Tenable as software or hardware flaws that are “unknown to a vendor prior to [their] public disclosure, or [have] been publicly disclosed prior to a patch being made available.” The firm identified 105 zero-day vulnerabilities in 2021, of which 83% are known to have been exploited in the wild. The report said that details of these weaknesses “are often kept under wraps” to prevent them from being exploited.

Two-thirds of the discovered vulnerabilities originated with just three companies: 28% in Microsoft products, 21% from Apple, and 18% from Google. Thirty percent of the vulnerabilities were detected in web browsers and 26% were in operating system software, with the rest found in web apps, email clients, office suites and other software products.

2021 zero-day vulnerabilities by vendor (Tenable) Content.jpg2021 zero-day vulnerabilities by vendor | Tenable

 

Tenable warned that while these vulnerabilities are “primarily leveraged in limited, targeted attacks” and therefore usually have limited impact at first, cybersecurity professionals cannot afford to disregard their dangers.

“The true value of a zero-day vulnerability is often not defined by its exploitation prior to discovery, but by the blog posts and proof-of-concept code published in the weeks and months after disclosure,” Tenable said. “Zero-day vulnerabilities typically become more problematic for most organizations after they’ve made the transition to legacy status, particularly if an organization has not yet applied available patches before widespread exploitation begins.”

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NRC Finds Cybersecurity Deficient at Davis-Besse

The Nuclear Regulatory Commission this week ruled that the Davis-Besse nuclear plant in northwest Ohio violated cybersecurity rules and ordered it to develop new procedures.

The plant also now faces a series of stepped-up inspections to make sure its staff are following the new cybersecurity procedures.

NRC noted in a letter made public this week that Davis-Besse and its owner Energy Harbor, headquartered in Akron, agreed to a cybersecurity “performance deficiency” during a Dec. 6 closed-door meeting with the commission but disagreed about how significant the lapses were. The company has 30 days to appeal.

The commission uses a four-color code to signify the seriousness or significance of the citations it issues, which determines the subsequent level of future inspections the citations will bring.

A “green” citation indicates a minor infraction, without further significance, similar to a warning that law enforcement might issue to a speeding motorist. More serious citations are “white,” the next level, or “yellow,” leading to increasingly wider and more intrusive inspections. The fourth color is “red,” the most serious citation, typically leading to inspections of multiple systems, often plant-wide, all of it billed to the plant owner.

NRC stated the cybersecurity citation is “greater than green” but did not specify how much greater, meaning the citation is at least a “white” finding and could be “yellow” or even “red.” Cybersecurity violations are not publicly explained in detail, nor are appeals made public. Companies are by law not permitted to discuss publicly the details of cybersecurity violations. Energy Harbor did not return phone calls seeking comment.

The company is simultaneously opposing NRC findings on a maintenance issue at Davis-Besse that could affect the entire commercial nuclear industry.

Energy Harbor is fighting a preliminary citation that Davis-Besse’s failure over 15 years to inspect and clean electrical switches controlling the power output of the plant’s two emergency diesel generators (DGs) led to their failure to actually generate power when they were started during routine testing. In other words, the diesel engines fired up, but their generators did not produce power.

The preliminary finding was issued in December. (See NRC Preparing to Cite Davis-Besse Nuclear Plant on Safety Issue.)

Emergency DGs are crucial safety equipment capable of powering emergency cooling and other systems during a reactor shutdown and a simultaneous loss of power from the transmission grid. They are not often used, but when they are, they must work. That’s why nuclear plants have two, one of which is a backup.

An NRC “greater than green” citation that the electrical switches controlling the output of the generators require scheduled maintenance could have industry-wide significance because every nuclear plant is equipped with emergency DGs.

During a two-hour teleconference with NRC this week, the company’s engineers argued the that the failure of the electrical contacts in the switches was inherent in the materials used to make them and not because of lack of maintenance.

The commission is not expected to make a final ruling on the switches until March.

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California PUC Weighs Changes to Contentious Solar Plan

The California Public Utilities Commission said Thursday it will delay indefinitely a vote on its controversial plan to reduce net metering payments to rooftop solar owners as it considers rewriting the proposal.

The proceeding, led by former Commissioner Martha Guzman Aceves, is now in the hands of new President Alice Reynolds, who previously served as energy adviser to Gov. Gavin Newsom.

“The assigned commissioner [Reynolds] has requested additional time to analyze the record and consider revisions to the proposed decision based on party comments,” Administrative Law Judge Kelly Hymes wrote in an email to parties in the proceeding.

“The proposed decision, which was issued on December 13, 2021, will not appear on the commission’s voting meeting agenda until further notice,” Hymes said.

In an email to clients, ClearView Energy Partners said, “We regard [this] as perhaps the strongest indicator from the CPUC to date that significant changes to the proposed decision are likely. On this point, we reiterate our long-held view that the final decision may move more toward the recommendations from solar advocates.”

The “provision most susceptible to change” is a proposed $8/kW grid participation charge that has particularly irked homeowners, ClearView said.

California Sen. Diane Feinstein wrote to Reynolds on Jan. 25, recommending that the CPUC reconsider the grid participation charge “to spur adoption of this technology.”

“The fee structure should properly reflect the benefits of distributed generation and promote wide adoption of rooftop solar,” Feinstein said.

Newsom, too, has said he thinks the plan needs work. (See CPUC Takes Heat on Rooftop Solar Plan.)

Opponents of the plan spoke in public comments at the CPUC’s Jan. 27 voting meeting for more than eight hours, leaving only a short time at the end of the day for the commission to take up its scheduled business. (The net metering proposal was expected to be taken up at the meeting, the earliest date on which it could be heard, but the CPUC did not put it on the agenda.)

The proposed decision, released in December, would reduce electric bill credits for homeowners with rooftop solar arrays by up to 80% and add the monthly grid charge to their bills. (See California PUC Proposes New Net Metering Plan.)

In the decision, crafted by Guzman Aceves and Hymes, the CPUC said the current net metering scheme unfairly shifts costs from homeowners who can afford rooftop solar to those who cannot.

It “negatively impacts nonparticipating customers, is not cost-effective and disproportionately harms low-income ratepayers,” Hymes wrote.

Estimates of the annual cost shift have ranged from more than $1 billion to $3.4 billion.

Opponents, led by the solar industry, have contended it will decimate rooftop solar adoption.

Homeowners who purchase rooftop solar arrays and return electricity to the grid have never paid a connection fee and are compensated at full retail rates, which are more than utility-scale solar costs. California has approximately 1.3 million rooftop solar arrays as a result of the generous incentives, advocates argue.

Those who support the CPUC’s proposed decision, including the state’s large investor-owned utilities, argue utility-scale solar is more cost-effective and can serve far more consumers that rooftop arrays.

Hymes said in her email Thursday that she would update parties on the next steps.

“After additional analysis is conducted, I will issue a subsequent ruling providing information on the proceeding schedule and details regarding the oral argument hearing,” she said.

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Coalition Forms for Consumer Choice in Retail Energy Markets

Six independent power producers and electric retailers announced Thursday they have formed a new organization to promote renewable energy and lobby states for greater customer choice.

The Retail Energy Advancement League (REAL) said it will push for more consumer control over the purchase, production and consumption of electricity, data usage and energy services.

REAL spokesperson Kate Philips said the organization believes “customer empowerment can be a lever” for aiding the transition to a low-carbon power system. Philips said REAL’s set of principles include putting control of energy decisions in the hands of consumers and a belief that “advanced competitive retail energy markets” can aid in the “modernization” of energy markets.

The founding companies of the group are IPPs Calpine Energy, NRG Energy (NYSE: NRG) and Vistra (NYSE: VST) and green retailers CleanChoice Energy and IGS Energy. Retailer Constellation Energy (NASDAQ: CEG), which separated from Exelon this week, serves as a founding associate member.

“Americans deserve easily accessible energy choices that reflect their lifestyle goals and choices,” said NRG CEO Mauricio Gutierrez, chair of REAL. “It’s time to allow competitive energy markets to drive innovation and put the power in the hands of people.”

REAL’s Board of Director’s include Gutierrez, Vistra CEO Curt Morgan, CleanChoice Energy President and CEO Tom Matzzie, IGS Energy President and CEO Scott White and Calpine Energy President and CEO Jim Wood. Its first CEO is expected to be announced at the National Association of Regulatory Utility Commissioners’ Winter Policy Summit in Washington later this month.

Maryland, Pennsylvania, Arizona

The group says it believes “competitive retail suppliers should be the entities tasked with helping customers achieve their energy goals.”

Philips said companies are motivated more today to invest in clean energy solutions, and a market that “enables regulated utilities to focus on maintaining and improving the state’s power infrastructure” can promote investment in new technologies.

REAL plans on having a “strong presence” in state capitals across the country, Philips said, and wants to work with other groups with shared goals. REAL is already teaming up with the existing Choose Who You Use electricity consumer campaigns in Maryland, Pennsylvania and Arizona.

Philips said polls consistently say customers want choice in their energy decisions. She said REAL will look to make policy decisions “based on what’s best for our customers in states across the country.”

“We think the market works better when the satisfying the consumer is the driving incentive, and not just whatever monopolies can convince regulators to let them charge their monopoly customer base,” Philips said. “Whenever they are polled, people say they want choice — and do not understand why energy is the single sector where they don’t have it. Every state that offers customer choice, but has chosen to put limits on it, has a waiting list out the door.”

Listening to Consumers

REAL officials cited a 2018 survey by Consumers Union, publisher of Consumer Reports, that gauged consumers’ attitudes toward their utility companies.

The findings included customers agreeing with the statement “I want to be able to choose my electricity provider” by a 10-to-one margin, with 76% supporting increased use of renewable energy. The survey also found that an additional 48% of all Americans would be willing to pay $5 more per month to buy 100% renewable energy.

Travis Kavulla, vice president of regulation for NRG Energy, said in a Twitter thread on Thursday that there is “a lot of work to be done” to make sure customers that already have a choice in their energy provider are “educated and empowered” in knowing their options and finding ways to improve their options.

“In every other part of our society we empower individuals to make the decisions that are best for their families and their businesses,” Kavulla said. “The electric sector stands out like a sore thumb — even at a time when we are more and more relying on it to drive a transition.”

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GSA, DOD Gear up to Meet Biden’s 100% Clean Energy Goal

The U.S. government, which buys more than 9 TWh of electricity per year from competitive retail markets, issued a request for information Thursday in its first step toward ensuring all that power will be carbon-free by 2030.

President Joe Biden set that goal in December, with his executive order on federal sustainability and energy procurement (EO 14057).  The order calls for each federal agency to “increase its percentage use of carbon pollution-free electricity, so that it constitutes 100% of facility electrical energy use on an annual basis, and seek to match use on an hourly basis to achieve 50 percent 24/7 carbon pollution-free electricity, by fiscal year 2030.”  (See Biden Calls for Federal Procurement of 100% Clean Energy by 2030.)

The RFI is a joint effort by the General Services Administration and the Department of Defense and particularly seeks input from power providers and other stakeholders in the PJM, ERCOT, ISO-NE, MISO and NYISO markets. The deadline for submitting comments is March 7.

Annual targets for carbon-free electricity (CFE) procurement across these markets include:

  • A minimum of 100-250 GWh for each of the five RTOs and ISOs or
  • 500-1,000 GWh for ERCOT and PJM or
  • more than 1,000 GWh for PJM only.

In a press release announcing the RFI, Federal Chief Sustainability Officer Andrew Mayock said that leveraging that kind of “scale and procurement power” will allow the Biden administration to “accelerate the development of America’s emerging clean tech industries,” create jobs and help American businesses compete in global markets.

The RFI guidelines use a broad definition of carbon-free electricity, ranging from solar, wind and geothermal to nuclear, “renewably sourced hydrogen” and fossil fuels with carbon capture and storage “that meets EPA requirements.”

But the guidelines clearly lean toward renewables and set high standards for potential projects. For example, the government would prefer carbon-free procurements that provide “new or previously underutilized generation sources” and that are located within a grid operator’s service territory. The expectation is that these procurements could spur 10 GW of new clean energy development across the country by 2030, the RFI says.

Further, to avoid any appearance of greenwashing, the RFI also requires new renewable projects to come with bundled renewable energy credits (RECs), indicating that the government wants to ensure the RECS are retired, rather than being sold to offset a utility’s or corporation’s carbon emissions.

The government expects the CFE procurements “to be integrated into existing electricity procurements in a phased approach over several years, through both the transition of existing retail supply contracts, and where appropriate, new power generation procurements,” the RFI says.

The GSA and DOD want to start phasing in contracts for clean power this year, with deliveries beginning in 2023.

Noting that the DOD is one of the largest electricity users in the U.S., Deputy Secretary of Defense Kathleen Hicks said the RFI will signal to the market the government’s intent to play a leading role in the energy transition. “It’s not just critical to addressing the threat of climate change, but also to our national security as we work to secure U.S. competitiveness in rapidly shifting global energy markets,” Hicks said.

24/7 Clean Power

The big question now is whether and how individual RTOs and ISOs will be able to meet the government’s goals. While ambitious, figures on current renewable generation and projected growth suggest the CFE procurement targets are achievable.

PJM Generation by Fuel Source (Monitoring Analytics) Content.jpgPJM generation by fuel source | Monitoring Analytics

According to figures from FERC, renewable energy represented 85.9% of new generation in the U.S. in the first 10 months of 2021, and the National Renewable Energy Laboratory has reported that interconnection queues across the country are backed up with 750 GW of wind, solar and storage projects.

Coming up with 250 GWh may not be a big stretch for ISO-NE, which at present supplies about 500 GWh to the federal government and had almost 19,500 GWh of renewables, including hydro, in its generation mix in 2021, 19% of its generation.

Similarly, at 7,500 GWH per year, PJM is the government’s top retail market power provider and, as of 2020, was producing more than 30,000 GWh from wind and solar. PJM is planning to change its rules for connecting new wind and solar projects to the grid so that shovel-ready projects will go to the head of the queue. The proposed changes would also streamline approval for projects that do not require a facilities study or any network upgrades. (See PJM PC/TEAC Briefs: Jan. 11, 2022.)

The bigger challenge may be meeting the executive order’s requirement that 50% of the power procured be able to match demand hour for hour around the clock. For example, the RFI guidelines do not include energy storage as part of annual calculations of 100% carbon-free energy but can be included as part of a portfolio of resources to meet the 24/7 power matching requirements.

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ERCOT’s Jones Works to Regain Texans’ Trust

One day at a time, one person at a time.

That is what it will take ERCOT to regain the trust of Texans scarred by last February’s disastrous winter storm, interim CEO Brad Jones told RTO Insider on Tuesday night.

To illustrate his point, Jones related his chance encounter with a woman following a town hall meeting in the Dallas suburb of Coppell. It was one of three dozen or so stops on his listening tour that eventually became a “blur,” but one of few he won’t soon forget.

He and another staffer were walking to their car in the parking lot, hoping they wouldn’t find their tires slashed. A woman then approached Jones and the staffer, who reacted warily.

“Living in Austin, I assumed she was going to ask us for money,” Jones recalled. “She grabbed both my hands and told me her story, what she had been through and how it had affected her family. I told her how important it was to us to ensure that doesn’t happen again.

“And then she said the most amazing, most Texan thing to say,” he said. “She said, ‘I will pray for everyone in ERCOT,’ and then she disappeared back into the darkness. Being true to my promise to that woman is why I’m here.”

Jones followed that up with a second story dating back to a conservation alert last summer, when ERCOT asked its consumers to reduce their energy usage to compensate for a drop in wind production amidst thermal maintenance outages.

Speaking from the grid operator’s operations center in Taylor, where he keeps a cot in his office, Jones said a buddy happened to be in town during the conservation alert and visiting his Austin home. The friend called his girlfriend in San Antonio to see how she was doing.

“She blasted back, ‘I’ll be a lot better when that [expletive] at ERCOT lets me turn up my air conditioning,’” Jones said. “I understand that frustration and anger. I also applaud that she believes it was a responsibility that every Texan should take on, to help other Texans.”

Of course, it will take more than prayers and Texans’ conservation measures for ERCOT to comfortably meet demand during the current winter storm. Nor do staff see this week as a test; they see it as normal business, Jones said.

“After listening to [customers’] stories, it makes it so much easier to discuss with them the improvements we’re making and to build confidence in what we’re trying to achieve,” Jones said. “One afternoon or evening in Midland is not going to change the people of Midland and rebuild their trust, but it’s a place to start, right? I’ve told them that in order for us to rebuild their trust, it’s not operating one winter well or five winters well. It’s 100 winters well, but we have to start somewhere.”

ERCOT Grid Conditions (ERCOT) Content.jpgERCOT’s operating reserves Thursday morning. | ERCOT

So far, so good. The grid operator’s December inspections of power plants found nearly complete compliance with the state’s new winter readiness regulations. Staff reported almost 7 GW of generation outages Thursday afternoon, below what staff say is normally 10 to 12 GW.

The grid operator’s conservative approach to the grid has resulted in more than 9 GW of reserves Thursday afternoon, thanks partially to wind resources’ overperformance. Wind was accounting for about 27% of the grid’s production during the middle of the day Thursday.

“The grid remains strong, reliable, and it is performing well in this winter weather event,” Public Utility Commission Chair Peter Lake said during a Thursday press conference.

ERCOT is currently expecting demand to peak around 73.5 GW Friday morning, which would exceed last year’s record winter peak of 69.2 GW before the load sheds began. Experts and academics have concluded demand could have reached 77 GW or higher last year, had the grid operator not been forced to cut load and compensate for the loss of about 50 GW of generation.

Local customer outages reached 70,000 at one point Thursday but had dropped to almost 37,000 as nightfall approached, according to PowerOutage.us. Texas Gov. Greg Abbott said 10,000 restoration crews are currently at work, with another 2,000 expecting from neighboring mutual assistance utilities.

Of more concern are natural gas supplies. As has been frequently noted, the state’s gas industry has not been required to winterize its facilities yet, something that is a year or two off. Bloomberg reported Thursday that 5% of the country’s gas production has been knocked offline by the freezing weather and that production declines will continue.

Jones has a plan there. Given the lack of transparency into the natural gas transportation system, he told the ERCOT Board of Directors last month that he wants to add a gas desk in the operations center to monitor gas availability or restrictions. (See ERCOT Preps for 2nd Cold Snap of Year.)

“That covers the biggest weakness we have,” Jones said, noting ISO-NE and NYISO already have similar desks. ERCOT first looked at the idea in 2015, but Jones thought it a wasted effort “because we’ll never get the information we need from the gas companies.”

However, with the new Texas Energy Reliability Council, power and gas representatives are in the same room for twice-weekly meetings, exchanging information and conversation.

“It’s really encouraging. I think we can fill that [information] gap,” Jones said.

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ERCOT Issues Watch as Winter Storm Nears

ERCOT issued a watch on Wednesday as cold weather began to tumble into the state, saying it is taking action ahead of an expected increase in demand to ensure grid reliability. The watch is effective through Sunday.

“We are ready for this storm. We will be prepared for this,” interim CEO Brad Jones said during a press conference Tuesday with other Texas officials, including Gov. Greg Abbott (R).

The grid operator’s weather forecasts indicate a “potential for significant frozen precipitation behind this week’s cold front,” Jones said in a statement.

The National Weather Service has issued a winter storming warning for Central Texas and a winter weather advisory for the rest as part of a 2,000-mile-long stretch of ice and snow that The Weather Channel has dubbed Winter Storm Landon. Temperatures are expected to be the lowest so far for the Lone Star State.

ERCOT currently expects demand to peak at 71.97 GW on Friday morning. That would break the record peak of 69.2 GW before the grid nearly collapsed during last February’s winter storm.

Jones said during the press conference that ERCOT expects to have about 86 GW of capacity to meet demand on Friday. The grid operator continues to operate conservatively, increasing operating reserves, bringing more generation online sooner if needed and procuring more ancillary services. It has also delayed generator maintenance and asked that units return from maintenance before the front hits.

Staff recently completed hundreds of winter-readiness inspections of generation, transmission and distribution facilities to check their compliance with new regulations. ERCOT said it found only three with deficiencies.

Greg Abbott (Office of the Texas Governor) Content.jpgTexas Gov. Greg Abbott during Tuesday’s press conference, with PUC’s Peter Lake and ERCOT’s Brad Jones (left to right). (Office of the Texas Governor) | Office of the Texas Governor

“We feel very comfortable about their level of readiness,” Jones said.

Abbott, who is up for re-election and fending off primary challengers to his right, has said since November that the lights will stay on this winter, a promise echoed frequently by Peter Lake, his appointed chair of the Public Utility Commission.

On Tuesday, Abbott acknowledged that “no one can guarantee that there won’t be a ‘load-shed event.’” He went on to say that outages will likely be at the local level because of icing power lines and trees falling onto lines.

“But what we will work and strive to achieve — and what we’re prepared to achieve — is that the power’s going to stay on across the entire state,” Abbott said.

Jim Wright, chair of the state’s natural gas regulator, the Texas Railroad Commission, countered concerns that the industry remains a weak link by saying that inspections have found 98% of natural gas facilities have been winterized. He said the 10 to 12 GW of gas plant outages during an earlier cold snap “were not anything out of the normal.”

However, the Houston Chronicle reported that its review of the inspection reports indicated that only 41% of the oil and gas facilities had successfully tested their weatherized equipment or procedures.

Jones said ERCOT is already aware of gas restrictions affecting as much as 2.6 GW of energy production this week, primarily in the Dallas-Fort Worth area.

ERCOT issues a watch when extreme cold weather is imminent and expected to have a negative effect on its footprint.

The Texas grid operator previously issued an operating condition notice Jan. 27 and a notice of “extreme cold weather event with potential icing conditions” on Monday. (See ERCOT, SPP Prep for Latest Wintry Blast.)

SPP Declares Resource Advisory

SPP raised its initial cold weather advisory issued Monday to a resource advisory on Tuesday for its entire Eastern Interconnection footprint. The notice was effective Wednesday through Saturday.

The RTO declared the advisory because of outages, wind forecast uncertainty, cold weather and icing’s effects on generation resources. Resource advisories do not require conservation measures but do serve notice to utilities in the grid operator’s balancing authority that SPP may use greater unit commitment notification time frames. This includes committing the footprint’s long-lead resources to account for possible icing on wind units.

A spokesperson said SPP does not currently expect to progress to more extreme advisories or alerts at this time. “We are relying on our diverse fuel mix and coordinating closely with our members,” Meghan Sever said.

The National Weather Service is predicting up to a quarter-inch of ice and as much as 6 inches of snow in central Oklahoma. Flights out of the state are being canceled, and schools began closing on Wednesday.

Kansas and Missouri are also expected to see signification snow fall this week.