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October 6, 2024

SPP Board Reviews 2021 Performance Metrics

SPP’s Board of Directors gathered virtually Monday to review performance metrics and stakeholder feedback for 2021 in what they hope will be their last remote meeting after almost two years of virtual gatherings.

“Clearly, everyone’s ready for in-person meetings,” CEO Barbara Sugg said.

She said not every board member filled out their surveys this year, a contrast to the normal 100% response rate. Including the Members Committee (MC), which advises the board, the rate was down from 81% to 75%.

“[Board Chair] Larry [Altenbaumer] and I will have to figure out a way to get people excited about filling this out next year,” she said.

The average board and members’ scores increased in 13 of 19 categories, dropping in only five. The average rate for meeting effectiveness fell from 4.50 to 4.43 (on a five-point scale) from 2020.

COO Lanny Nickell said SPP’s annual organizational effectiveness survey of its 21 stakeholder groups saw its lowest scores for member preparation and engagement during meetings. Members rated the groups’ overall effectiveness at 4.40 on a five-point scale, down slightly from 4.42 in 2020.

Larry-Altenbaumer-Barbara-Sugg-(SPP)-Content.jpgBoard Chair Larry Altenbaumer and CEO Barbara Sugg adjourn the SPP board’s final meeting of the year. | SPP

 

The response rate to the RTO’s annual stakeholder satisfaction survey was up slightly from 2020 to 13.8%, but still down from the high-water mark of 21.2% set in 2017. The survey was distributed to 1,672 organizational group members, market participants and other individuals who interacted with SPP during the previous 12 months through meetings, training, customer relations interactions or other exchanges.

Respondents indicated a slightly lower overall satisfaction with SPP’s service in 2021, with scores falling from 3.87 in 2020 to 3.61, similar to ratings in 2018 and 2019. The average scores evaluating staff’s performance in three specific areas also declined by an average of 6.3% year-over-year, falling in line with 2018 and 2019.

David Osburn, Oklahoma Municipal Power Authority’s general manager, suggested stakeholders might be experiencing fatigue from the number of high-level initiatives SPP has taken on during the last two years.

“The last two years have been incredibly fatiguing, and not just because we’re dealing with this remote world,” Sugg said. “We’ve just had some really big things that have taken so much time. I hope that doesn’t lead to us providing less quality service … we have to start delivering on all those things we’ve decided to take on.”

“I think the organization, the staff, board and stakeholders did just a fantastic job navigating through these past two years,” Altenbaumer said. “I know we’re all anxious to get into 2022, when the world will start moving in something that feels more normal.”

SPP plans to resume its in-person meetings in January after two years of COVID-19 pandemic restrictions. The board, MC and Regional State Committee will meet Jan. 24-25 in Little Rock, Ark., while the Markets and Operations Policy Committee and Strategic Planning Committee (SPC) will meet Jan. 10-12 in Oklahoma City.

New Groups, Stakeholder Reps OK’d

The board also unanimously approved two new stakeholder groups, chairpersons for several working groups and advisory groups, and two representatives for empty seats on the SPC, all brought forward by the Corporate Governance Committee.

The Emergency Communications User Forum’s creation was one of several recommendations made by SPP’s comprehensive report on February’s winter storm. The group will be responsible for providing feedback to identify, improve and prioritize SPP stakeholders’ energy emergency communications needs.

SPP staff proposed forming the Future Grid Strategy Advisory Group to “proactively address, drive and shape” some of the grid’s anticipated changes and to prepare for other changes.

Named as stakeholder group chairs were:

  • Allen Klassen, Evergy, Operating Reliability Working Group;
  • Robert Pick, Nebraska Public Power District, Regional Tariff Working Group;
  • Thomas Maldonado, Xcel Energy, Reliability Compliance Advisory Group;
  • Jim Jacoby, American Electric Power, Seams Advisory Group;
  • Phil Clark, Arkansas Electric Cooperative Corporation, Security Advisory Group;
  • Natasha Henderson, Golden Spread Electric Cooperative, Supply Adequacy Working Group; and
  • Derek Brown, Evergy, Transmission Working Group.

Usha Turner, Oklahoma Gas & Electric, and Steve Sanders, Western Area Power Administration, will join the SPC. Turner’s term ends in December 2023 and Sanders’ in December 2024.

MISO Raises ORDC’s Lowest Level to $1,100/MWh

FERC on Monday approved MISO’s request to raise its four-step operating reserve demand curve’s (ORDC) lowest level from $200/MWh to $1,100/MWh, agreeing with the RTO that the final step is probably priced too low to entice generating resources (ER21-2797).

MISO’s ORDC is based on a $3,500/MWh value of lost load (VoLL) and begins at $3,300/MWh. It drops to $2,100/MWh for much of the curve when the RTO clears 8% of its requirement level. At 89%, the level falls to $1,100/MWh, remaining there until 96% or more of the requirement is cleared and the curve flattens at $200/MWh.

The fourth step will be raised to equal $1,100/MWh, better reflecting the cost of emergency actions necessary to meet reserve shortages.

In its filing, the RTO said the $200/MWh step undervalued reserve shortages and led to “inefficiently low prices that did not send signals to resources that may be expected to respond in future shortage conditions.”

FERC agreed that the $200/MWh price might not send appropriate signals to resources “and could lead to procurement of reserves below system need.”

MISO staffers have said the $200/MWh value was set before the grid operator had established emergency pricing. They have long said the starting point should be raised to reflect the value of energy in scarcity conditions.

The change should help raise the grid operator’s emergency prices, which MISO’s Independent Market Monitor has long criticized as too low. The IMM has called for an operating reserve demand curve that eradicates the step-based pricing in favor of gently sloped descent from a much higher starting point of about $10,000/MWh.

MISO has said it doesn’t plan to address raising its VoLL value until 2023 or later.

Hawaii PUC Approves Kauai Pumped Storage Project

Hawaii’s Public Utilities Commission last week approved construction of the West Kauai Energy Project (WKEP), a pumped storage hydropower (PSH) project designed to provide the island with 110 GWh in annual output.

Located on the west side of Kauai near the town of Waimea, WKEP will be constructed and operated by AES and owned by the Kauai Island Utility Cooperative (KIUC).

WKEP is a multifaceted project that will generate electricity via hydropower, store and release electricity using a solar PV/battery-electric storage system (BESS) and provide irrigation to support nearby agriculture.

The PSH will utilize two powerhouses with the PV/BESS. Water will flow from diverted rivers down the mountain into the Puu Lua Reservoir. From there, some water will be diverted to irrigation while the rest will flow down to the Puu Opae Reservoir and its powerhouse, generating 4 MW or an estimated 13 GWh annually. The water will then flow down to the Mana Reservoir and its powerhouse, generating 20 MW or an estimated 13 GWh annually.

The PV/BESS system near the Mana Reservoir will generate 35 MW, some of which will go directly to Kauai’s energy grid, and the rest will go to pumping the water from the Mana Reservoir back up to the Puu Opae Reservoir in a continuous loop.

KIUC estimates that from the energy produced from PV, 48% will be used to power the Mana Pumphouse, 31% will go directly to Kauai’s energy grid and 21% will be sent to the BESS.

The PUC order (38095) approving the project notes that the BESS “will be DC-coupled to the PV array and thus will be able to follow the variability of the PV array’s energy production caused by passing cloud cover to ensure constant PV power for pumping while also harvesting otherwise clipped/lost energy.”

KIUC says the project will provide reliability through energy storage, noting the PSH portion of WKEP will offer “firm, dispatchable renewable energy, averaging 26 GWh annually, that can be delivered to the grid mainly during the evening peak, nighttime and morning peak hours but also during periods of cloudy/rainy weather, thereby displacing fossil fuel energy.”

The utility expects the project to reduce fossil fuel use by 8.5 million gallons annually, which would allow the project to contribute 22.72% to KIUC’s renewable portfolio standard (RPS). In addition, KIUC estimates that WKEP will offset approximately 2.5 million GHGs over the project’s lifecycle.

KIUC estimates that WKEP will save its customers “between $157 million and $172 million” over 25 years.

The project will also rehabilitate the Puu Lua Reservoir for community recreation. KIUC also notes that WKEP “should assist in mitigating future flooding risks. … The repairs to the Puu Lua Reservoir, Puu Opae Reservoir and Mana Reservoir will bring the reservoirs into compliance with Hawaii State Dam Safety Standards, which [will] provide some protection from flooding for downstream lands and greatly decrease the risk of a dam breach.”

Kauai residents and environmental groups previously raised concerns about WKEP related to land use for solar panels, the location of piping for the hydro portion of the project and the potential for discharge of fresh water into nearby coral reefs. (See Kauai Solar + Pumped Hydro Project Raises Concerns.)

Residents asked that the PUC not approve the project until it undergoes a Hawaii Environmental Policy Act (HEPA) review, but the commission accepted KIUC’s assurances that it would provide quarterly updates regarding the review and reserved the right to take “appropriate” action in response.

AES can begin construction once a HEPA review has been completed and it has acquired all necessary permits for construction and operation.

Decarbonizing America’s Ports Could be 1st Step for Hydrogen Adoption

The anticipated revolution in hydrogen-based fuels advocated by the Biden administration and endorsed by the U.N. Convention on Climate Change has also captured the imaginations of green visionaries eager to help the world dodge climate change by ending dependence on fossil fuels.

One such organization is the California-based Green Hydrogen Coalition, an educational nonprofit founded in 2019 with the mission to build “top-down momentum for scalable green hydrogen projects.”

Janice Lin, the Berkeley-based founder and president of GHC, sees the nation’s seaports as an ideal starting place for a hydrogen fuel revolution to begin “because ports are epicenters of poor air quality.”

In a two-day webinar hosted Nov. 30 and Dec. 1, Lin moderated multiple panels of experts and advocates to examine that proposition while also examining strategies to leverage green hydrogen, made with electrolysis using renewable power. Nearly all of the hydrogen used today is stripped from natural gas, which also produces carbon dioxide and, because of that, is known as gray hydrogen.

Day 1 of the conference included an overview of the Biden administration’s hydrogen goals and the $9.5 billion in funding authorized to accelerate the development of clean hydrogen in the $1 trillion Infrastructure Investment and Jobs Act that the president signed into law Nov. 15.

Viewers also heard the experience of one marine terminal company servicing the congested Port of Los Angeles: Fenix Marine Services, which moves about 20% of the port’s cargo and consumes about 175,000 gallons of diesel fuel every month.

Webinar participants and viewers also got a brief analysis of the global hydrogen market from a BloombergNEF analyst who predicted green hydrogen would become a dominate fuel in most major markets by the end of the decade.

Targets

For the federal perspective, U.S. Deputy Energy Secretary David Turk made it clear that hydrogen is a cornerstone of the administration’s energy policy, whether green, gray or blue — the last of which is when the carbon dioxide produced when making hydrogen from methane is captured and sequestered or used in some other industrial process.

“Hopefully everyone has now seen and internalized this administration’s incredibly ambitious goals on climate: the 2030 goal of 50 to 52% … greenhouse gas emission reductions; 2035, 100% clean electricity; and 2050, full net-zero for our economy,” Turk said.

Reaching those targets will require “a range of technologies, not only for electricity but for transportation; for buildings; for industry; across everything that uses energy in our society,” he said.

“One of those technologies that we’re putting a lot of emphasis on, certainly from the Department of Energy perspective, is hydrogen. It’s versatile; it can be created in a number of different ways. It can be used in a number of different ways, including for the harder-to-decarbonize sectors, whether that’s heavy-duty freight, whether that’s a variety of industrial uses. But there’s some challenges on hydrogen, especially the cost of green hydrogen,” he said.

The administration’s ultimate goal for hydrogen is to create an industry with the ability to produce it carbon-free at $1/kg by the end of the decade, he said.

And that fits well with GHC’s goals to convince terminal operators in the ports of L.A. and Long Beach to shift away from diesel-powered trucks and other equipment as soon as possible and move to electric equipment, powered either by hydrogen fuel cells and batteries or plugged into the local distribution gird.

Advocacy group C40 Cities has that same goal but on an international basis.

“The idea behind our ports program is that by engaging ports and shipping industry, city governments can align their climate goals and strategies, and not just share knowledge but act collectively as a coalition,” said Alisa Kreynes, green ports program manager for the group’s Climate Solutions & Networks division.

“We see point cities as key global players and catalysts for decarbonizing our shipping and supply chains. We also see ports and cities having a unique role in climate action because of the very nature of how ports connect cities across the world through trade and innovation,” she said.

C40 in April began developing common emission standards for ports and working with both utilities and shipping companies to create “the world’s first transpacific green shipping corridor,” a pilot program to  shipping companies to deploy zero-carbon-emission vessels running on green hydrogen.

“By 2030, we want to see deep sea container ships operating on zero-carbon-emission fuels. How many ships are realistic by 2030 on a specific trade route will be determined through the study we will need to undertake to understand the fuel supply and the bunkering infrastructure requirements,” Kreynes said.

C40 is also interested in developing ship-to-shore policies aimed at cutting down diesel emissions from both docked ships and those waiting offshore for a berth at a terminal.

“We’re looking at shore power requirements to be absolute for all container vessels,” she said of the policy still in development.

“So regardless of the types of fuels [used], all ships will still need to plug in. The same goes for cargo handling equipment, which will be electric or powered by green hydrogen [fuel cells]. [A] zero-carbon-emissions requirement is a must by 2030.”

Collaboration with Industry

But none of this can be done without the participation of the industry itself.

“We need terminal operators; we need cargo owners; we need harbor craft companies; and we need fuel producers. So this is the coalition that has been working to put together this really exciting pilot, which we are hoping to be able to announce very soon,” Kreynes said. She added that the Port of L.A. will be leading the effort that will include overseas ports as well.

Those goals dovetail with the efforts of Pacific Environment, a California-based nonprofit that works to foster “grassroots activism” in communities around the Pacific Rim, whether in North America or Asia.

Madeline Rose, campaign climate director for Pacific Environment, described her organization as “a shipping industry watchdog,” noting that it has “gained a permanent consultative status of the International Maritime Organization, which sets international shipping law.”

“We’re now leading a global advocacy campaign to force the transition of ships off fossil fuels,” she added. “Fossil fuel shipping is just a massive global polluter. The industry accounts for 3% of global climate emissions today” and is annually adding to its emissions, she said.

But how to pressure the industry to switch to cleaner alternatives is the question.

About half of the maritime pollution comes from container ships, and Pacific Environment has determined that 15 container ship companies account for about 97% of the products sold by U.S. retailers. The major clients of container shippers include companies such as Walmart, Amazon and Costco, and they carry products made by companies such as Nike and Patagonia — all of which have “ambitious climate commitments.”

“They are vulnerable to public pressure because they have a direct relationship with all of us,” she said.

Rose added that Pacific Environment is also targeting smaller vessels: tugboats, ferries, dredges, excursion vessels and fishing boats that routinely ply the waters of most ports. She said the California Air Resources Board is moving toward new regulations “to encourage a zero-emission transition for all registered commercial harbor craft in California. We’re expecting that regulation to pass the Air Resources Board around January or February.”

But it won’t require immediate electrification, she added. “As written, it’s going to allow a vast majority of the vessels to either upgrade to cleaner diesel engines or electrify.”

The adoption of the new rule means that “over 1,000 vessels with hundreds of different companies in the next several years will be looking to partner with other organizations to make the transition to electrification, which includes green hydrogen fuel cells,” she added.

And that includes the federal government. “The U.S. government is one of the largest owners of harbor craft in the world,” Rose said. “The U.S. government owns 1,700 Harbor vessels.”

Discussion with Scott Schoenfeld — general manager of Fenix Marine Services, which relies on a fleet of more than 350 large diesel-powered equipment and vehicles to move tons of good through the L.A. and Long Beach ports — revealed just how difficult it will be to make the transition from fossil to hydrogen.

“My problem is that my business, which supplies the goods our nation needs and the exports we produce, is almost completely reliant on heavy machinery that is powered by diesel fuel,” he said.

“Roughly 40% of the containerized freight comes through the twin ports of L.A. and Long Beach, and containerized freight represents more than 90% of the goods you see on the store shelves.

“Fenix has made the switch to renewable diesel, purchased hybrid machines, purchased carbon credits and installed energy storage devices. But we currently still have no commercially viable option to purchase and power either battery electric or hydrogen fuel cell zero-emission port equipment. …

“We’re working on it. We’re piloting a lot of different options, but it’s a lot more than just being able to say ‘we’re going to do it’ and expect it to happen. … Our initial estimates show that if Fenix were to fully electrify our terminal, we would more than quadruple our electrical demand, from an already stretched electrical grid. … We face multiple brownouts and blackouts on a yearly basis, and this prevents us from doing our jobs and supplying all the goods that we need.”

The company has partnered with Toyota and took delivery of its first fuel cell-powered utility tractor rig (UTR) in November. The rig loads containers from ships onto heavy-duty trucks.

The Port of L.A. in June also deployed five fuel cell Class 8 trucks manufactured by Kenworth Trucks and powered by Toyota fuel cells, in a test of the technology. It expects to take delivery of another five trucks, as well as battery EVs, in the future. They use gray hydrogen.

Schoenfeld said Fenix would move quickly to fuel cell-powered UTRs and trucks if hydrogen were available at less than $3/kg.

Future Prices

Cheap green hydrogen looks as if it could be a reality by the end of the decade, according to BloombergNEF analyst Matthew Bravante.

In a separate discussion, Bravante said green hydrogen today is not competitive anywhere in the world because there is so little of it and because it is so expensive, at as much as $14/kg.

But, given its endorsement and funding by multiple governments, intense ongoing research — and the expected arrival of increasingly less expensive renewable energy to power electrolyzers that are also expected to drop in price — the cost of green hydrogen will dramatically decline, he said.

“By 2030 [the median price] will out-compete … blue hydrogen in nearly every major market. And in some major markets, you’ll start to see green hydrogen out-compete gray hydrogen,” he said.

“Within the next handful of decades, you’ll see a total paradigm shift in the cost of hydrogen, from green carbon-free hydrogen being the most expensive to green carbon-free hydrogen being the cheapest,” he predicted.

Initial demand for green hydrogen will come from refining and companies using ammonia to make fertilizers. Its use as a fuel for residential and commercial heating will likely follow as prices fall.

But even at $1/kg, hydrogen will may still not be cheap enough to decarbonize the entire economy, he said.

“The point I want to make is that hydrogen will start to decarbonize certain sectors at $2/kg, or $1.50/kg, or even $1/kg. But in order to fully decarbonize whole industries with hydrogen, you will still need some sort of carbon pricing mechanism,” he said, touching an issue that most politicians today regard as “the third rail” in any energy debate.

Pennsylvania Leaders Celebrate 25th Anniversary of Deregulation Law

It’s been a quarter-century since Pennsylvania took the step to fundamentally change its energy market to give customers the ability to choose their own electric supplier, encouraging them to shop around and compare prices.

Former Gov. Tom Ridge signed the Electricity Generation Customer Choice and Competition Act of 1996 into law on Dec. 3 of that year, and business and energy leaders of today gathered virtually on Tuesday to talk about the impacts of the legislation that resulted in Pennsylvania customers paying electricity rates lower than the national average after being one of the most expensive states in the country for electric generation.

Data from the Pennsylvania Public Utility Commission shows that more than 1.5 million residential and 300,000 non-residential customers have taken advantage of the program, being provided more than 85 million MWh of electricity.

Nora-Mead-Brownell-(PGE)-Content.jpgFormer FERC Commissioner Nora Mead Brownell | PG&E

Nora Mead Brownell, former FERC commissioner and a founding partner of ESPY Energy Solutions, sat on the Pennsylvania Public Utility Commission when the law went into effect. She called the debate in the legislature at the time “intense,” with many outside pressures influencing its development.

Brownell said while she’s excited to see what happens in the future with the competitive market program, its benefits have already created lasting impacts on the state, ranging from declining carbon emissions caused by retiring uncompetitive coal-fired generators to increased capacity and efficiencies for nuclear plants, “bringing value to customers.”

One of the “amazing” parts of the development of the competitive market, Brownell said, was the number of customers who chose to source their generation from green energy even though it was more expensive, something that wasn’t anticipated. Brownell said that choice sent a market signal, leading to investment in renewable energy like large wind farms in the western part of the state.

“Markets send signals, and individuals have options to express their preference,” Brownell said.

Business Impressions

Kevin Sunday, director of government affairs for the Pennsylvania Chamber of Business and Industry, said the state “took a major step forward” in 1996 in the restructuring of its electricity markets. Sunday said the legislation “turned into a national example” of how to take risks off ratepayers and place them on the private sector where they could compete on prices and foster more efficiencies.

Over the last 25 years, Sunday said, Pennsylvania not only became the largest power producer in PJM, but it is now the largest net exporter of power of any state in the country. He said the energy exports to PJM are a “boon for reliability,” driving investments to areas of need.

“This landmark law has provided a foundation for energy policy long into the future,” Sunday said. “By empowering businesses and individuals with the choice to select the energy that makes the most sense for them, and rewarding innovation, the economy and the environment both win.”

Rod Williamson, executive director of the Industrial Energy Consumers of Pennsylvania (IECPA), said there were three key benefits to the legislation for large industrial customers.

The first was more competitive pricing, Williamson said, pointing to data from the Energy Information Administration that showed Pennsylvania had the ninth highest industrial electricity rates in the U.S. in 1995, a year before the law. In 2020, Pennsylvania ranked 30th in industrial electricity rates, coming in below the national average.

A second benefit was greater pricing flexibility and structuring the electricity supply. Williamson said companies are now able to lock in prices for years in advance, allowing for greater budget certainties and the ability to adjust operations to utilize lower market prices in off-peak times.

The third benefit was greater flexibility in the type of generation and the ability to seek lower carbon forms of generation. Williamson said some industrial customers are demanding more renewable energy sources, and the competitive electricity market allows them to control the type of renewable generation they’re purchasing.

“It’s for these key reasons that IECPA supports competitive energy markets and regulatory structures that facilitate a consumer’s use of these markets,” Williamson said.

David Taylor, CEO of the Pennsylvania Manufacturers’ Association, said energy is one of the most important inputs for manufacturing, which makes up $93 billion of Pennsylvania’s economy. Taylor said enormous amounts of energy are consumed in the manufacturing process, and it’s a major “advantage” for the state to have “affordable, reliable, market-priced electricity.”

Taylor said the health of the manufacturing sector leads to the health of Pennsylvania’s economy.

“Competitive markets are foundational to Pennsylvania’s future economic success, and there is no going back,” Taylor said. “This is a benefit all consumers enjoy, but especially large energy-consuming manufacturing employers that employ the most people, add the most value and have the strongest multiplier effect on economic growth.”

Past and Future

When asked about the biggest challenge that had to be overcome in getting the competitive market law enacted in 1996, Brownell said “misinformation” and a desire by generating companies to remain the “monopoly provider” of electricity. She said competing goals led to a “brutal battle” with “enormous” amounts of political pressure.

Brownell said she didn’t blame generating companies who wanted to retain their positions, but as a policymaker, her job was to “deliver value for the customers, large and small.” She said the resulting jobs created as well as the resilience and reliability of the electricity supply from the competitive markets have all been “critically important” to the state.

As for the future of the competitive market, Brownell said there continues to be a challenge of educating the public on the benefits of the markets. She said the lower prices are the most visible benefit, but the resulting innovations have created a more resilient electric system.

Brownell said one action that can be taken is continued review and evaluation of the program to foster improvements.

“There’s no change that can’t be improved by continuing to evaluate outcomes, so it’s not a once and done deal,” Brownell said. “Markets evolve, so we need to continue to evolve to find better ways to help customers make different choices and expand the opportunity for them to manage their own energy use.”

PUC Narrows Options for ERCOT Market Redesign

Texas regulators have settled on a two-phase blueprint to redesign the ERCOT market after a half-dozen work sessions and have given stakeholders until noon Friday to pass judgement on the proposal.

The first phase involves revisions to the operating reserve demand curve (ORDC) and additional ancillary services products. That will set the stage for the second phase, which the commissioners said will involve a load-side reliability mechanism and a backstop reliability service.

In a memo issued Monday, the Public Utility Commission of Texas said it had agreed in principle to continue pursuing the Phase 1 market design changes and has committed to developing the Phase II elements. It has requested comment on Phase II only by Friday, with stakeholders limited to five pages and an executive summary (52373).

“We can show the markets, the legislatures, our state leadership, and more importantly, the citizens of Texas, that we are continuing to make long-term reforms that will solve the problems at hand,” PUC Chair Peter Lake said during Thursday’s open meeting.

Independent consultant Alison Silverstein, who has offered her own design recommendations, said the blueprint is “unnecessary and inappropriately hurried” because the long-term proposals addressing the ERCOT system’s near-collapse during February’s winter storm will have no effect on what happens this winter.

“The electric reliability of the world’s ninth-largest economy demands thoughtful planning and careful analysis, not a rash rush to judgment with little stakeholder and no public input,” Silverstein told RTO Insider. “The commission needs to take the time to solidify and assess the impacts of the substantive measures already under way … upon operational reliability, resource revenue flows, wholesale and retail markets, and customer costs.”

Silverstein said the memo ignores one of Texas’ biggest reliability problems: that many of ERCOT’s black start units weren’t working during Winter Storm Uri.

“If Chairman Lake wants to rush something, let’s rush black start reform, please,” she said.

The various proposals’ costs have also played little part of the PUC’s discussions. The Brattle Group said last month that the load-serving entity (LSE) obligation would cost the ERCOT market an extra $300 million a year. (See Texas PUC Ponders Alternatives to LSE Obligations.)

“The LSE [obligation] … would push Texas much closer to a costly capacity market,” Stoic Energy’s Doug Lewin said. “The goal has to be to achieve high reliability at the lowest cost. Is there any analysis at all to determine what the impact will be? Or the reliability impacts? I don’t understand how the PUC could move forward without more analysis.”

‘Too Much of a Good Thing’

The commissioners did offer some pushback against the LSE obligation and other proposals during last Thursday’s latest work session, asking for more time to digest the proposals and gather stakeholder feedback.

“I want to make sure whatever we are doing to significantly modify our market is actually going to drive more dispatchable generation and maintain our existing fleet,” Commissioner Lori Cobos said. “I don’t want any unintended consequences.”

A flustered Lake responded by saying, “Lack of action has consequences, too, that can be severe.”

“While analysis and due diligence is important, action is also important,” he said. “Endless studies will not help Texans and solve our problems. I don’t want any good ideas to be sacrificed on the altar that prices can’t go up.”

The commission said the load-side reliability mechanism will be developed according to a set of principles that include offering economic rewards and providing “robust” penalties or alternative compliance payments based on a resource’s ability to meet established standards; building on ERCOT’s existing renewable energy credit (REC) trading program framework; providing a forward price signal to encourage investment in dispatchable generation; use dynamic pricing and sizing to ensure reliability needs are met without over-purchasing reserves; and mitigating market-power concerns for generation companies that also serve retail customers.

The commissioners plan to consider adopting the LSE obligation, championed by Lake since its proposal earlier this fall in a study funded by generation heavyweights NRG Energy and Exelon. The study’s authors say the LSE obligation would directly address resource adequacy concerns by introducing a formal reliability standard and a mechanism to ensure sufficient resources meet this standard. (See Study Suggests Texas LSEs Can Provide Reliability.)

The PUC will also add elements from a Lake strawman and Commissioner Will McAdams’ dispatchable energy credits (DEC) proposal. The latter recommendation would establish a dispatchable portfolio standard for certain qualifying generators to create the DECs, which would be bought, sold or traded is the same manner as RECs.

The commissioners also said they have agreed to develop a backstop reliability service that would procure accredited new and existing dispatchable resources as an insurance policy to help prevent emergency conditions. The service’s principles include non-performance penalties and clawbacks for noncompliance; deploying resources in a manner that doesn’t negatively affect real-time energy prices; and allocating costs to load based on a load-ratio share basis measured on a coincident net-peak interval basis.

In the meantime, the commission wants to modify the ORDC to reward “reliable” generation assets that can be dispatched as ERCOT’s reserve margin drops. The changes, to be effective Jan. 1, would set the minimum contingency level (MCL) at 3 GW and eventually decouple the systemwide offer cap and the value of lost load.

The PUC cut the high systemwide cap from $9,000/MWh to $5,000/MWh during last Thursday’s open meeting. (See Texas PUC Pushes 44% Reduction in ERCOT Offer Cap.)

Other products, including a firm fuel product, fast-frequency response service, ERCOT contingency reserve service and expansion of existing non-spinning reserve service already are underway.

However, that left at least one commissioner wondering whether that was too much of a good thing.

“I feel like I’m getting whiplashed with all these new products we’re creating,” Commissioner Jimmy Glotfelty said during Thursdays’ open meeting. “I almost feel like we’re creating niche markets. I hope we’re not cannibalizing our own system and we’re doing good for our market.”

National Electric Highway Coalition to Build Fast-charging Stations

More than 50 electric utilities across the U.S. announced the creation of a national coalition Tuesday to facilitate the buildout of fast-charging stations on major highways in most states, giving electric vehicle owners the ability to travel distances by the end of 2023 without range anxiety.

The Edison Electric Institute “and our member companies are leading the clean energy transformation, and electric transportation is key to reducing carbon emissions across our economy,” EEI President Tom Kuhn said in a statement. “With the formation of the National Electric Highway Coalition, we are committed to investing in and providing the charging infrastructure necessary to facilitate electric vehicle growth and to helping alleviate any remaining customer range anxiety.”

The coalition is expected to focus initially on the nation’s interstate system.

The U.S. Department of Energy estimates there are currently about 6,800 fast-charging stations in the country and nearly 47,000 slower public charging stations. A DC fast charger can repower the batteries of  many new EVs to 80% in 20 to 30 minutes, according to ChargePoint, a California-based EV infrastructure company. Older hybrid EVs may not be equipped to take the high voltage of a fast charger.

The $1.2 trillion Infrastructure Investment and Job Act, which President Biden signed Nov. 15, allocated $7.5 billion for alternative fuels, including a buildout of a national EV charging network.

EEI estimates that member utilities have already spent more than $3 billion on “customer programs and projects to deploy charging infrastructure and to accelerate electric transportation.” As of February, 31 states and D.C. had approved electric transportation filings made by 52 companies, EEI previously reported.

The organization estimates there are about 2 million EVs on the road today, less than 1/10 of the 22 million expected by 2030. It has estimated that EV drivers will spend the equivalent of about $1.20/gallon, based on average U.S. residential rates.

Monitor, Merchants Challenge ISO-NE Plan to Eliminate MOPR

Merchant generators joined ISO-NE’s Internal Market Monitor on Tuesday in warning that the RTO’s proposal to eliminate the minimum offer price rule (MOPR) will suppress prices.

Other stakeholders debated whether the implementation of the RTO’s plan should be delayed until it approves long-term market rule changes on capacity accreditation and reserves.

The NEPOOL Markets Committee is scheduled to vote on the RTO’s proposal at its first meeting next year, Jan. 11-12. Stakeholders interested in proposing amendments should notify the committee secretary by Jan. 3 for inclusion on the agenda.

The RTO’s proposal was prompted by calls by FERC Chair Richard Glick and Commissioner Allison Clements to abolish the MOPR, which they said were undermining state decarbonization efforts. (See ‘Good Riddance’ to Old PJM MOPR, Glick Says.)

The IMM’s David Naughton and Michael Redlinger outlined their concerns with the RTO’s proposal at a daylong MC meeting, acknowledging that the MOPR prevents some state-sponsored renewables resources from clearing the Forward Capacity Market (FCM), undermining decarbonization efforts and causing “over-procurement.”

But they said the rule has been effective at limiting the impact of below-cost offers on the capacity market. “Inadequate mitigation rules may undermine the efficiency of the FCM in performing its function and ability to produce just and reasonable rates,” they said in a presentation.

They also acknowledged that efforts to address the tension between price formation and states’ generation preferences — such as the renewable technology resource (RTR) exemption and substitution auction under the Competitive Auctions with Sponsored Policy Resources (CASPR) — “have had limited results.”

But they said the RTO should be pursuing long-term market changes that could help, saying “net carbon pricing” could reduce the “missing money” for low-carbon generation while being compatible with the current broad MOPR.

Allowing sponsored resources to clear the auction “leads to essentially walking down the FCA [Forward Capacity Auction] demand curve,” they said. “MOPR elimination will allow [subsidized] resources to offer at a lower cost than they otherwise would absent the subsidy, in many cases down to $0.”

The price suppression and volatility could result in premature retirements and lead investors to demand higher returns on investment, shorter pay-back periods or long-term contracts, they said.

ISO-NE’s proposed buyer-side mitigation (BSM) rules would exempt subsidized resources, resources of 5 MW and less, energy efficiency, and projects whose sponsors self-certify they have no load obligations that could benefit.

The Monitor said the BSM rules would focus on uneconomic conduct that impacts prices for the benefit of a “net” or “leveraged” position. Project sponsors would have the option to demonstrate that there is no incentive — no net financial benefit — to exercise buyer-side market power.

“But the exercise of market power can take many forms, and the IMM is focused on the impact on price formation from below-cost offers regardless of whether to benefit a load position,” it said. “Mitigation needs to address market power in whatever form when it would impair competitive market outcomes.”

The Monitor said the focus on sponsors’ lack of incentive to suppress prices would allow the sponsors to decide what information to provide to the monitors.

“This limits the IMM’s ability to evaluate and determine whether the declaration of no material net benefit is accurate and hence the lack of mitigation warranted,” it said. Current rules, it noted, require market participants to provide “all” relevant information.

Merchants Share IMM Concerns

Bruce Anderson, of the New England Power Generators Association (NEPGA), said his group shares the Monitor’s concerns.

“The conditions under which the FCA would need to clear to produce just and reasonable rates … appear to create significantly increased risks to either reliability, market efficiency (reliability-must-run agreements) or perhaps to both,” NEPGA said. “Alternatively, those risks do not materially increase, but the market produces unjust and unreasonable rates.”

NEPGA said the RTO should not eliminate the MOPR until it implements long-term rule changes such as effective load-carrying capability (ELCC) and wholesale market designs that compensate resources for reliability services the RTO doesn’t pay for now. “These necessary market reforms would provide some measure of balance in a proposal that at present fails to balance consumer and investor interests,” Anderson said.

Anderson questioned why the RTO is pushing the MOPR elimination given that FERC has not issued an order requiring  such action. “The proposal attempts to satisfy a mandate and deadline that does not exist,” he said.

Andrew Weinstein of Vistra (NYSE:VST) took a similar position. Vistra proposed a transition, which Weinstein said “buys time for long-term durable solutions to better align with complete MOPR elimination.”

Long-term solutions such as ELCC or a reserves product “cannot be achieved in the timeline set forth by ISO-NE,” he said. ISO-NE’s proposal, he said, could create “market risks that will remain unresolved until long-term designs can be approved.”

Vistra called for a two-year transition period for FCAs 17 and 18, with the MOPR eliminated for FCA 19.

The rule would remain in place with an RTR exemption of 300 MW for FCA 17 and 400 MW for FCA 18. Between 229 and 292 MW of sponsored resources cleared in FCAs 13 to 15. There would be no weighted average cost of capital adder while the MOPR is intact, and the net cost of new entry (CONE) would also remain unchanged until FCA 19.

Weinstein noted that the RTO has embraced several out-of-market designs to address reliability issues over the past decade, yet it has conducted no study of how removing MOPR would impact the ability to serve load.

“Given the reliability risks and legal and policy risks of immediate and complete MOPR elimination, regional consensus on a long-term durable solution is strongly preferable,” he said.

Enviros: No Need for Transition

The Natural Resources Defense Council and Conservation Law Foundation, however, said no transition is warranted. Because the region is currently oversupplied, they said, it has sufficient time to address the long-term market changes.

“We know where the region is headed, and new entry from state clean energy resources is known well in advance,” NRDC’s Bruce Ho said in a presentation. He said the failure of the CASPR initiative to integrate state clean energy resources “has already led to unnecessary delays and consumer costs.

“Delaying MOPR elimination could result in [an] FCM that fails to incorporate clean energy through the end of this decade,” he added.

While the groups said they support ISO-NE’s approach to removing the MOPR, they questioned the RTO’s proposal to adjust CONE financial inputs, noting that the normal CONE/net CONE cycle allows consideration of multiple market and rule changes.

“Tariff, policy and market changes happen every year, and we have never adjusted CONE between cycles to address them,” Ho said. “What makes this change so different?”

LS Power Responds to ISO-NE Criticism

LS Power used its time to defend its proposed Scarcity Event Reduction Framework (SERF), which it said would provide “incremental incentives” for investing in flexibility and reliability in time for FCA 17.

The construct would credit or charge resources for their energy and reserves supplied when real-time reserve prices are positive.

The proposal is based on the current Pay-for-Performance (PfP) design but would increase the instances in which performance is assessed. While PFP design assesses performance only when there is a capacity scarcity condition (CSC) — triggered by a shortage of a minimum real-time reserve requirement — SERF would apply the new credits and charges whenever there is a positive real-time price for reserves but no CSC.

LS Power’s Mark Spencer said changes are needed to restore the balance between buyers and sellers because “there is no tangible risk of a scarcity event, and the adverse selection problem raised in the 2014 PfP filing has yet to be addressed.”

He noted there has been only one event — lasting about 2.5 hours — in the last four summers, although the RTO predicted a handful of hours in every year. In the last five years, 7 to 9 GW of capacity resources that obtained a capacity supply obligation in the FCA — more than 20% of the total on average — did not participate in the peak load hour.

PfP-Risk-Perspective-(LS-Power)-Content.jpgLS Power wants ISO-NE to go beyond eliminating the minimum offer price rule (MOPR) and embrace broader proposals to incentivize generator performance. In the last five years, 7 to 9 GW of capacity resources that obtained a capacity supply obligation — more than 20% of the total on average — did not participate in the peak load hour, it said. | LS Power

Eliminating the MOPR will “further reduce the already miniscule probability of scarcity events,” he said.

Spencer said the proposal was an effort to address “a market in distress that requires immediate attention.” Market design efforts the RTO has in its work plan such as ELCC and day-ahead co-optimization “will not materially improve this situation,” he said.

In a Dec. 3 memo, ISO-NE said it opposed the proposal because it would incentivize resource owners to offer in the real-time energy market at prices below their marginal cost and ignore dispatch instructions.

Spencer said the RTO’s concern that some resources would offer below their cost when it anticipates a SERF event to avoid penalties is not realistic because it would require “perfect foresight” to make the strategy profitable. A resource would have to predict a SERF event at least 30 minutes in advance.

LS Power said SERF events would usually be less than one hour and may be spread over two delivery hours, while real‐time reoffers are binding for an entire delivery hour. “Frequently part of the hour would be unprofitable, offsetting the profit‐making potential in the rest of the hour.”

SERF events would occur infrequently — only 13 days, or 7.6% of the summer peak days — during the last two years.

“The ISO’s analysis … ignores the cost of those days when the generator submits a below-cost offer but a SERF event doesn’t occur,” Spencer said.

MC Vice Chair, Committee Secretaries

Also Tuesday, the committee re-elected Sigma Consultants’ William Fowler as vice chair. No other members expressed an interest in the position, the RTO said.

Earlier this week, ISO-NE announced committee secretaries for 2022:

  • Dennis Cakert, who recently joined the RTO as a lead analyst in the NEPOOL Relations team, will serve as secretary to the MC. He previously was the senior manager of regulatory affairs and state policy with the National Hydropower Association (NHA).
  • Marc Lyons, who has served as the Reliability Committee secretary for 12 years, will become secretary for the Transmission Committee.
  • Nicholas Gangi. who recently joined the RTO as a lead analyst in the NEPOOL Relations team after working as an engineer with Eversource Energy, will be secretary of the Reliability Committee.

NY Climate Action Council Focuses on Consumer Impacts

New York officials on Monday tweaked the state’s draft scoping plan on climate action to include cost/benefit and consumer impacts analyses as soon as possible.

Donna-L-DeCarolis-(NYDPS)-Content.jpgDonna L. DeCarolis, National Fuel Gas Distribution | NYDPS

“To wait until after implementation to assess impact seems too late,” Donna L. DeCarolis, president of the National Fuel Gas Distribution Corp., told the state’s Climate Action Council.

The CAC will meet Dec. 20 to vote on a final draft scoping plan for achieving the goals laid out in the Climate Leadership and Community Protection Act; the plan will be discussed over the course of 2022 before implementation the following year. Monday’s meeting was an ad hoc extension of a Nov. 30 session that ran out of time. (See NY Predicts 200K+ New Clean Energy Jobs by 2030.)

Several council members asked that energy affordability and consumer pricing impacts be included within the draft scoping plan, but the integration analysis that provides the overall economy-wide costs doesn’t actually get to the ratepayer impacts, said Sarah Osgood, executive director of the council.

“In order for us to get to the ratepayer impacts you need to have specific details on a policy, and since we’re not at that level of detail staff is recommending that specific ratepayer costs would be identified as part of a subsequent implementation process,” Osgood said.

Lack of Data?

The council was asking for feedback in relation to a proposed resolution essentially saying that it cannot at this point in time include ratepayer cost impacts of every particular policy that’s included in the scoping plan, Osgood said.

Sarah-Osgood-(NYDPS)-Content.jpgSarah Osgood, NYCAC | NYDPS

Known costs certainly could be articulated in the draft scoping plan, said Gavin Donohue, president and CEO of the Independent Power Producers of New York.

“There are recommendations where I would readily admit that we maybe don’t know the cost today, but where we have recommendations that the NYSERDA [New York State Energy Research and Development Authority] or the Public Service Commission can determine the actual customer cost, I think that should be analyzed to be part of a scoping plan,” Donohue said. “Without that I think it’s a real incomplete report and a disservice to the public.”

Much robust cost and impact analysis is happening in New York, but the council should push for better coordination between state agencies to gain macro efficiencies, said Raya Salter of NY Renews.

Gavin-Donohue-(NYDPS)-Content.jpgIPPNY CEO Gavin Donohue | NYDPS

The PSC can look into affordability and macro efficiencies that can be captured, but it’s a challenge to fit these critical pieces into the plan correctly in the next week or so, Salter said. The process would also be helped by the council getting an update from the Climate Justice Working Group on the definition of what constitutes a disadvantaged community, she added.

Osgood agreed to put that update on the Dec. 20 agenda.

“We have not yet resolved the question of who would ultimately pay for some of these initiatives and or policies,” council Co-chair and NYSERDA CEO Doreen Harris said. “We not only have to analyze the costs themselves, but also the question of who is paying is a related challenge.”

A compromise could be that when the council’s work reaches the point of a specific regulatory proposal, it recommends that there has to be a specific ratepayer assessment at that time, said Anne Reynolds, director of the Alliance for Clean Energy New York.

Calculating Benefits

Several council members reminded their colleagues that cost/benefit analysis included the word “benefit,” and that sometimes the benefits will outweigh the costs.

Thomas-Falcone-(NYDPS)-Content.jpgLIPA CEO Thomas Falcone | NYDPS

For example, installing air-sourced heat pumps will drive customer electric bills up because they’re using more electricity, but their heating bill will go down, said Thomas Falcone, CEO of the Long Island Power Authority.

“At least on Long Island, even at today’s natural gas prices and oil prices, there’s a huge benefit to moving to electrification,” Falcone said. “About 40% of Long Island customers use oil heat, and if you move those oil heat customers to an air-source heat pump, it saves them a ton of money.”

Total energy use goes down rapidly with heat pumps, and that’s why the emissions are going down, said Robert Howarth, professor of ecology and environmental biology at Cornell University.

“I just want to highlight that because it’s exactly the same case that beneficial electrification applies equally in the heating sector and in the transportation sector,” Howarth said.

PJM Operating Committee Briefs: Dec. 2, 2021

PJM is looking to create guidance and requirement language for several manuals related to the implementation of a dynamic line rating (DLR) system in the RTO.

Chris Callaghan, senior business solution engineer with PJM’s applied innovation department, presented a first read of a problem statement and issue charge at last week’s Operating Committee meeting.

Transmission lines are typically operated using a static rating calculated for periods of time using near worst-case values for predicted weather conditions, but DLRs can be calculated in real time and show the resulting weather and other environmental impacts to the line ratings.

Callaghan said DLR deployments in PJM will involve the installation of a data collection sensor on or near an existing transmission line to collect real-time conductor temperature information. The sensor technologies that will be deployed in PJM include weather stations, electromagnetic field detectors and thermal cameras.

While different sensor technologies exist, Callaghan said, PJM wants to see the DLR installation projects have a common goal of targeting congested transmission facilities where the conductor is the most limiting element.

PJM has identified several manuals that may require new language for the incorporation of DLRs. The updates include section 2 of Manual 1 related to member control center requirements, section 2 of Manual 3 on thermal operating guidelines and appendix A of Manual 3A on the transmission equipment rating monitor equipment ratings update process.

The proposed problem statement calls for the incorporation of supporting manual language to ensure the “efficient and reliable operation” and use of equipment DLR systems in various aspects of operations, markets and planning. Callaghan said the opportunities driving the effort include reliability and economic benefits associated with DLR technology.

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Adrien Ford, ODEC

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“The interest here is transparency to members and the reliability mission of PJM,” Callaghan said.

Expected deliverables in the issue charge include stakeholder education of DLRs and potential new or modified governing language in the manuals.

Callaghan said PJM was looking to use the “CBIR Lite” (Consensus Based Issue Resolution) process to come up with a single proposal. The discussions would occur at normal OC meetings and are expected to take more than two months.

Adrien Ford of Old Dominion Electric Cooperative said she disagreed with using the CBIR Lite process and had anticipated more expected deliverables and key work activities in the issue charge. Ford said PJM should be “very careful” to keep the issue narrow if the RTO wants the DLR work done quickly in the OC.

Calpine’s David “Scarp” Scarpignato said he was hoping for a deliverable focused on the placement of DLRs on the grid. Scarp said DLRs are “very important to modernize the transmission grid,” but it will be necessary to make sure their placement is not discriminatory.

<img src="//www.rtoinsider.com/wp-content/uploads/2023/06/140620231686783195.jpeg" data-first-key="caption" data-second-key="credit" data-caption="

Sharon Midgley, Exelon

” data-credit=”© RTO Insider LLC” style=”display: block; float: none; vertical-align: top; margin: 5px auto; text-align: left; width: 200px;” alt=”Midgley-Sharon-2019-03-06-RTO-Insider-FI.jpg” align=”left”>Sharon Midgley, Exelon | © RTO Insider LLC

Scarp also said he doesn’t know what criteria and guidelines transmission owners plan to use for the installation of DLRs. “I think an important expected deliverable has to be criteria for where to implement DLR.”

Eric Hsia of PJM said the RTO recognizes the importance of DLR placement. Hsia said PJM wanted to focus on adding support language on the physical operations of DLR in the proposed problem statement and issue charge and that the DLR placement issue could better be handled at the Planning Committee in a separate problem statement and issue charge.

Sharon Midgley of Exelon said PJM should be “very careful” in doing a legal review to “respect” the delineation of responsibilities between the TOs and the RTO when it comes to decisions on the placement of DLRs on the transmission system.

“I get a little nervous when I hear things like new requirements and new criteria,” Midgley said.

The OC will be asked to approve the issue charge at the Jan. 13 meeting.

Renewable Dispatch First Read

Darrell Frogg of PJM’s generation department, presented a first read of a problem statement and issue charge to improve dispatching renewable resources and increase forward-looking visibility.

Frogg said PJM is already discussing renaming the issue to “intermittent resource dispatch” instead of “renewable dispatch” to better align with existing language in the RTO’s governing documents. Frogg said PJM wanted to keep the issue broad to include all renewable resources.

The growing number of renewable resources on the grid has led to some “new operational issues and impacted existing issues,” Frogg said, including a greater dependence on the ability to accurately dispatch renewable resources in real time and forecast near-term changes. Frogg said as the number of renewable resources grows, manually managing dispatch becomes more difficult and leads to inconsistent performance when following curtailments and/or basepoints.

Frogg said PJM sees an opportunity to improve several main aspects of renewable dispatch, including developing a method that covers all renewable resources and a streamlined data exchange.

The key work activities of the issue charge include reviewing education on the existing renewable dispatch practices and the expectations from PJM and its members. The goal is to propose solutions to enhance the overall renewable dispatch process.

Areas in scope for discussion in the issue charge are the methods in which PJM dispatches renewable resources, communication of dispatch mode and instructions, and lost opportunity cost eligibility. Out-of-scope items include existing market products and calculations and ongoing revisions such as those related to FERC Order 2222 and the treatment of solar-battery hybrids. (See “Solar-battery Hybrid Resources,” PJM MRC/MC Briefs: Nov. 17, 2021.)

The expected deliverables in the issue charge are changes to resource expectations when dispatched in real time and manual language and potential governing document changes to reflect the proposal.

Work on the issue charge would take place in the OC or its special sessions, reporting out to Market Implementation Committee when needed. The work is estimated to take six months, and PJM was looking to pursue the CBIR Lite approach to develop a proposal.

<img src="//www.rtoinsider.com/wp-content/uploads/2023/06/140620231686783196.jpeg" data-first-key="caption" data-second-key="credit" data-caption="

David "Scarp" Scarpignato, Calpine

” data-credit=”© RTO Insider LLC” style=”display: block; float: none; vertical-align: top; margin: 5px auto; text-align: left; width: 200px;” alt=”dave-scarpignato-rto-insider” align=”left”>David “Scarp” Scarpignato, Calpine | © RTO Insider LLC

Scarp said he didn’t think the issue should be part of the CBIR Lite approach. He said PJM staff are “extremely well versed” on the issue and think it can be solved quickly, but the stakeholder process can take longer as members need to be brought up to speed on complicated issues.

“We may end up at the same positions as PJM, but we have to have time to get there in order to vote for it,” Scarp said.

Sean Chang of Shell Energy said he would like to see some education on comparing what other RTOs and ISOs are doing on the renewable dispatch issue.

“Some of the other areas with more renewable penetration have had some challenges operationally, and it could be helpful to compare and contrast,” Chang said.

The OC will be asked to approve the issue charge at its next meeting.

Manual 38 Changes

Liem Hoang of PJM reviewed proposed changes to Manual 38: Operations Planning as a part of a periodic review during a first read.

Hoang said the minor changes include updating the Eastern Interconnection Reliability Assessment Group study and PJM participation in the group. Language was added to state that the group will conduct “assessments to identify key reliability issues and the risks and uncertainties affecting adequacy and security of the bulk power system in the Eastern Interconnection.”

The OC will be asked to endorse the changes at its Jan. 13 meeting, with final adoption at the Markets and Reliability Committee meeting Jan. 26.