Page 553 – RTO Insider

December 3, 2021January 9, 2024

FERC Sets Hearing on Industrials’ Challenge to PJM Administrative Rates

FERC ordered hearing and settlement judge procedures on Wednesday in response to industrial customers’ protest of PJM’s proposed revisions to its administrative rates (ER22-26).

The commission accepted PJM’s proposed tariff revisions for filing and suspended them for a “nominal period” to become effective Jan. 1 while directing the appointment of a settlement judge within 45 days and the issuance of a report on the status of the settlement discussions 60 days after that.

FERC said its initial analysis found PJM’s proposed tariff revisions may be unjust and unreasonable.

PJM’s proposal called for changing its administrative cost recovery from the current practice of initial charges at stated rate levels with a varying quarterly refund to the new practice of monthly rates based on that month’s costs and that month’s billing determinations.

The RTO said the proposal was developed in conjunction with the Finance Committee and is “specific only” to schedule 9 of the tariff, which provides cost recovery for its subsidiary, PJM Settlement, Inc. The company provides billing, settlement, treasury and credit management functions for transactions in the PJM markets. Other schedules recover costs for FERC’s annual charges, the Independent Market Monitor and other entities that benefit the PJM region.

The schedule 9 changes received unanimous support from the Finance Committee in July. PJM said the administrative rate review was initiated to examine “rate equity” across its membership to avoid cross subsidization among the different customer classes and for “overall revenue adequacy.”

The proposal “adjusts with changes in usage patterns” of the services that PJM provides and the costs of providing the services; it was designed to avoid over- and under-collection of funds to finance the RTO.

Stakeholders endorsed the proposal and tariff revisions at the September Members Committee meeting. The proposal was endorsed with a sector-weighted vote of 3.84 (76.8%), and PJM made a filing with the commission on Oct. 1. (See “PJM Administrative Rates,” PJM MRC Briefs: Sept. 29, 2021.)

Disagreements

The PJM Industrial Customer Coalition (ICC) protested PJM’s filing, arguing that the proposal was “not supported by any quantitative analysis or evidentiary support, such as a cost-of-service study.” The ICC said PJM did not provide any explanation for using the number of invoices as the new billing determinant for schedule 9, and that for industrial customers that have multiple accounts for multiple facilities in PJM, the “cost implications of the per invoice weekly charge is substantial.”

The ICC said one of its members will see costs increase by 385%, while PJM “has not demonstrated that the cost to serve industrial customers with multiple accounts/invoices has uniformly increased by that kind of magnitude.”

PJM said the “vast majority” of settlement costs are fixed expenses, “reflecting the resources PJM Settlement must secure to conduct its activities.” The RTO said “more than half” of the ICC members were charged “little or nothing” under the current system.

FERC said it needed fact finding to determine “whether PJM has justified its proposal to show that its per invoice approach comports with cost causation principles.”

FERC Commissioner Allison Clements partially dissented to the order, saying she would have also set a hearing on whether PJM’s cost transparency procedures are sufficient.

“Having previously participated in different RTO stakeholder processes, I appreciate the value of clarity in procedures related to ensuring transparency,” Clements said in her dissent. “I am not convinced based on the record compiled to-date that the procedures outlined by PJM will prove adequate.”

PJM last filed to update its administrative rates five years ago. In December 2016, FERC accepted PJM’s proposal to increase its stated rates over an eight-year period, with a 7.5% increase in 2017 and a 2.5% hike annually between 2019 and 2024.

The RTO said it required the rate increase at that time because its stated-rate revenues had fallen below the level needed to recover its administrative costs.

December 3, 2021January 9, 2024

GAO Warns Feds Putting Off ‘Urgently Needed’ Cybersecurity Steps

The Government Accountability Office (GAO) warned on Thursday that the federal government has yet to take “urgently needed” actions to protect the nation’s critical infrastructure, including the electric grid, from cyberattacks.

In written testimony to the U.S. House of Representatives’ Transportation and Infrastructure Committee, Nick Marinos, GAO’s director of information technology and cybersecurity, highlighted incidents such as the ransomware attack against Colonial Pipeline in May, which led the company to shut down its entire network, temporarily halting nearly half the supply of gasoline, diesel and other fuel products to the U.S. East Coast. (See Colonial CEO Welcomes Federal Cyber Assistance.)

While the Colonial attack demonstrated that cyberthreats targeting critical infrastructure are growing rapidly, Marinos said that “GAO’s recommendation to develop and execute a comprehensive national cyber strategy is not yet fully implemented.”

Marinos specifically noted the lack of follow-through on GAO’s March report that spotlighted the vulnerability of electric distribution systems to cyberattacks. (See Distribution a Cyber Weak Point, GAO Warns.) In that report, GAO observed that the Department of Energy had no plans to study the impact of a cyber threat to these systems, much less mitigate it.

Marinos said that although DOE “agreed with our recommendation” the needed actions had not been taken as of November.

He also criticized the federal government for neglecting its role in protecting national critical infrastructure. GAO has made multiple recommendations in this regard as well, which Marinos chided the government for not following. (See GAO Pushes Agencies for Action on Resilience.)

A major focus of Marinos’ 24-page statement was the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency (CISA), established in 2018 to “[protect] federal civilian agencies’ networks from cyber threats and to enhance the security of the nation’s critical infrastructure in the face of both physical and cyber threats.” The Senate confirmed former Morgan Stanley executive Jen Easterly to head CISA in July. (See Senate Confirms Easterly as CISA Chief.)

GAO issued a report in March calling for organizational changes to CISA to address complaints about the agency from public- and private-sector stakeholders, including “lack of clarity surrounding its organizational changes and the lack of stakeholder involvement in developing guidance.” While these actions have not been implemented, Marinos said that DHS had “concurred” with them and plans to fully implement them by the end of next year.

GAO did win approval of its recommendation for creation of a National Cyber Directorate within the White House. The directorate’s first head, Chris Inglis, was confirmed by the Senate in June. (See Inglis, Easterly Define Roles in Confirmation Hearing.) Marinos called this an “important first step,” saying the cyber director can help coordinate the actions of various groups across government and perform oversight of their activities.

He likewise praised Inglis’ issuance of a strategic intent statement in October as a positive move.

Nevertheless, Marinos warned that the October document — which lays out a vision for the office and high-level lines of effort including planning and incident response, budget review and assessment, and federal cybersecurity goals — falls short of a true national cyber strategy, which he called “more urgent than ever.”

December 3, 2021November 8, 2023

California PUC Orders Procuring 3 GW of Capacity

The California Public Utilities Commission on Thursday adopted measures aimed at securing up to 3 GW of additional capacity through supply- and demand-side programs to prevent shortages in extreme heat waves in the summers of 2022 and 2023.

The measures include ordering the state’s three big investor-owned utilities — Pacific Gas and Electric, Southern California Edison and San Diego Gas & Electric — to accelerate procurement of battery storage and to increase production from existing natural gas plants, as well as increasing payments to demand response customers.

The CPUC projected shortfalls of 2 to 3 GW during the next two summers, but PG&E, SCE and SDG&E have already procured 1 GW in response to earlier commission decisions, President Marybel Batjer said.

“While the gap is large, I want to be clear that there is already significant procurement that can be used toward this need,” Batjer said.

Measures approved in three decisions Thursday include:

expanding the use of a central procurement entity to ensure local reliability served by community choice aggregators and other load-serving entities;
doubling the payment to participants in the CPUC’s Emergency Load Reduction Program to $2/kWh and paying residential customers the same rate for reducing use during grid emergencies; and
funding a $22.5 million smart-thermostat incentive program “designed to reduce air conditioning a few degrees during emergencies” and creating pilot programs “to test the effectiveness of dynamic rates that change rapidly in response to grid emergencies.”

Other measures allow PG&E to install additional temporary gas generators and authorize SDG&E to build four new microgrid projects totaling 160 MW. (See CPUC Proposes Summer Reliability Measures.)

Since late 2019, the CPUC has directed the state’s IOUs to collectively procure more than 17 GW of additional capacity, including a June order for 11.5 GW of new resources to come online between 2023 and 2026. The rolling blackouts of August 2020 and energy emergencies the past two summers lent urgency to the efforts.

Thursday’s actions were taken in response to an emergency declaration by Gov. Gavin Newsom in July that said the state could face up to a 5-GW shortage this summer. A subsequent CPUC analysis found the shortage to be 3 GW at most.

The commission cited the potential for continuing high temperatures, wildfires and drought in the West as reasons for boosting the planning reserve margin in CAISO territory to 20-25% in the coming summers.

The state’s increasing reliance on solar power — which ramps down as the sun sets — adds to the challenge, the decision said.

“This perfect storm of reliability challenges requires urgent action now,” it said.

December 3, 2021November 2, 2023

Vermont Landfill Solar Project Highlights Brownfield Challenges

Two recently completed solar projects in rural Vermont demonstrate how one developer overcame higher development costs for brownfield sites to help meet state environmental and clean energy objectives.

Burlington-based Encore Renewable Energy built a 2.2-MW solar project on a closed landfill and a 2.3-MW project on a former gravel pit in Jericho, Vt.

“By using these otherwise underutilized or undevelopable pieces of property, we’re essentially preserving additional greenfield space,” Encore founder and CEO Chad Farrell told NetZero Insider. “In Jericho, that could be conservation to maintain the most carbon sequestration possible or that can be housing or other commercial or agricultural land use.”

Both brownfield projects were challenging, but building a solar array on a landfill has an additional level of complexity from a permitting perspective that also affects project costs, Farrell said.

To build on a capped landfill, a developer must assure regulators that construction will not harm the environmental remediation already approved for the property. That remedy, Farrell said, can be a soil cap, and it might include a geomembrane between the waste and the cap. “We have to demonstrate that we’re not going to cause any additional erosion … or settlement.”

Adjusting construction to accommodate the environmental needs of the landfill affects the project timeline and labor needs, which makes it more expensive to develop than other projects, according to Farrell.

On other sites, construction vehicles can drive onto the property with installation equipment, but that’s not possible with a landfill. “We have to use smaller Bobcat rigs that have lower weight and lower tire or track pressure, and that just takes a lot more time.”

Jericho-Landfil-Solar-Aray-Close-Up-(RTO-Insider-LLC)-Alt-FI.jpg

A solar array on a closed landfill in Jericho, Vt., needed a special racking system that would not require driving posts through the soil that caps waste on the property. | © RTO Insider LLC

In addition, foundation posts, which typically sit 6 to 8 feet into the ground, cannot penetrate the 3-foot soil cap. And the cap wouldn’t have the stability needed for structures to withstand high wind forces.

For landfills, Encore uses ballasted foundations that Farrell said have enough weight to distribute the downward force of the panels over a wide area. Foundations at the Jericho site, he said, are prefabricated tubs that were filled with cement in the field.

Incentives Needed

With higher overall development costs comes a higher price per kilowatt-hour, which makes developing brownfields a significant market challenge.

In the case of the Jericho landfill, however, the local utility wanted to work with the community and bring the clean generation into one of its higher demand centers.

“Vermont Electric Cooperative was willing to sign on to a slightly higher [power purchase agreement] price for the landfill project in order to meet the town’s objectives of reusing that site, while also addressing their requirements under Vermont’s renewable energy standard.”

By pairing the landfill and gravel pit projects, Encore was able to achieve economies of scale and bring down the overall PPA cost to the utility, according to Farrell.

The dynamics that moved the Jericho arrays forward to completion would not be possible for all the developable landfills in the state.

“If the only projects that are selected in any kind of statewide selection process are all about the lowest per-kilowatt-hour price delivered, landfills can’t compete,” Farrell said.

Brownfields, carports and rooftops are statutorily defined in Vermont as preferred sites.

“That’s where the general public would like to see these generation assets,” Farrell said. “We have to do a better job of incentivizing these types of projects.”

The Vermont Climate Council’s recently adopted Initial Climate Action Plan calls for incentivizing solar development in “already altered locations” and discouraging siting new generation in “intact ecosystems.” It also calls for regulators to design a 100% renewable energy standard by 2030. Farrell is a legislatively appointed council member. (See Vt. Climate Council Adopts ‘Initial Climate Action Plan’.)

Landfills can only be one part of what Farrell sees as “multiple tranches” for solar development to help meet the state’s energy and environmental goals. Some landfills are challenging in terms of scale and topography, he said.

“Older municipal dumps often were only 1 or 2 acres, and they were built like a mound of trash, so they have excessive slope for us to be able to deliver even the ballasted racking projects,” he said.

That means the state needs a “mix and match” approach for the size of sites and projects it authorizes, he said. In addition to residential- and commercial-scale projects, and medium-scale brownfields, Farrells said Vermont needs 5-MW and larger facilities that might require 30 acres of open space, for example.

The large projects are “where we can really deliver solar at the lowest price points possible, which, in consideration of ratepayer impact, has to be part of the discussion,” Farrell said.

December 2, 2021June 14, 2023

NY Predicts 200K+ New Clean Energy Jobs by 2030

A study commissioned by New York officials predicts that clean energy employment in the state will increase by at least 211,000 jobs this decade and by nearly 350,000 by midcentury.

Philip Jordan, E3 | NYDPS

The preliminary results from the report by the Climate Action Council’s Just Transition Working Group also finds that 10 new jobs will be created for every job displaced through 2030 by the state’s move away from fossil fuels. The growth subsectors include electricity distribution and transmission, onshore and offshore wind, solar, battery storage, and the building and transportation sectors.

“That’s really enormous job growth … a rate that’s more than double the annual growth rate from 2016 through 2020,” Philip Jordan of Energy and Environmental Economics (E3), which conducted the study, told the council Tuesday.

Drilling into Data

Following a growth rate of 15% from 2016 to 2019, energy efficiency jobs declined by nearly 5% with the advent of the pandemic but have been rebounding since the low point of the second quarter last year, according to the state’s 2021 Clean Energy Industry Report recently released by the New York State Energy Research and Development Authority (NYSERDA).

Carl Mas, NYSERDA | NYDPS

At the end of 2020, there were approximately 157,700 clean energy workers in New York, and clean energy jobs comprised roughly 2% of all jobs in the state, but less than 1% of jobs lost in the economic downturn, said Carl Mas, director of energy and environmental analysis at NYSERDA.

Clean energy employment in New York a year ago was still about 12% higher compared to the 2015 baseline, Mas said.

Displacement of jobs could total 77,000 by midcentury, and the jobs study is intended to provide data to help officials develop workforce training and identify opportunities across the state, especially disadvantaged communities, Mas said.

One CAC member was surprised that the job growth isn’t greater between 2030 and 2050.

Robert Howarth, Cornell University | NYDPS

“There’s a pretty rapid increase until 2030, and then I would expect all sorts of actions need to be taken afterward, that they would increase it more,” said Robert Howarth, professor of ecology and environmental biology at Cornell University.

The large job growth early on stems from the inputs given to the team, Mas said.

To hit the state’s goal of 70% renewable electricity by 2030 requires “a massive level of investment in order to ramp up, and when we think about jobs, interestingly it’s not the absolute amount of capacity; it’s the annual scale of change that’s driving jobs each year,” Mas said.

Howarth also said that projected declines in gas station employment could be lowered by encouraging the creation of 440 fast-charge stations, which probably would feature cafes and convenience stores that would maintain the retail jobs.

Mas agreed and said that the scale of investments is starting faster than probably most analysts had expected five years ago.

“Because of that, we’re driving job creation sooner and then sustaining those jobs over time as we retrofit more homes and as we build and deploy more solar panels,” Mas said.

IPPNY CEO Gavin Donohue | NYDPS

Gavin Donohue, president and CEO of the Independent Power Producers of New York, asked if there was anything being done about non-energy manufacturing and job loss as a result of increased energy costs. The study talks about nuclear jobs being lost, but no licenses come up for renewal before 2029, he said.

The anomaly comes from the base year including the closure of the Indian Point nuclear station, Mas said.

“I understand that … though we’re talking about a decrease of use of natural gas as a state, but I didn’t see a job impact and changes in other industries like agriculture or farming,” Donohue said. “There has to be an impact in those sectors if we’re having impacts in other sectors, so that’s the question maybe we can answer later, but it’s an omission on the study’s part.”

Moving Forward

NYSERDA CEO Doreen Harris | NYDPS

NYSERDA on Tuesday finalized contracts with Clean Path New York and with Hydro Quebec Energy Services for the Champlain Hudson Power Express and filed them for comment and approval with the Public Service Commission, council Co-chair and NYSERDA CEO Doreen Harris announced.

“All told these are the largest transmission projects contracted for in New York state in the last 50 years and will reduce the city’s fossil fuel use for electricity by more than 80% in 2030 when combined with their other clean energy investments,” Harris said. (See Two Transmission Projects Selected to Bring Low-carbon Power to NYC.)

The two separate projects total 2,550 MW and will bring solar, wind and hydropower south to New York City.

The CAC will meet in December to vote on a final draft scoping plan for achieving the goals laid out in the Climate Leadership and Community Protection Act, which will be discussed over the course of 2022 before implementation the following year.

NYSERDA will bring forward benefit-cost analysis at the next meeting, and will also be exploring a sensitivity around higher adoption rates for ground source and district heat pumps, Mas said.

NYCAC-Meeting-2021-11-30-(NYDPS)-Content.jpg

The New York State Climate Action Council met virtually Nov. 30 to discuss a report on clean energy jobs growth this decade and through 2050. | NYDPS

Not every home and apartment in New York could adopt a ground-source system, so there would be a role for district heating that may be sourced by water or ground or other resources, Mas said.

“So we will be exploring that to give us some better insights into the technical feasibility and also some of those cost tradeoffs,” he said. “While it may be more expensive to invest in these upfront, we also will see system benefits through a smaller grid.”

December 2, 2021

NV Energy Gets Green Light for $100M EV Charger Plan

The Public Utilities Commission of Nevada has approved NV Energy’s $100 million plan for a network of electric vehicle charging sites throughout the state.

The commission voted 3-0 Tuesday to approve the proposal, called the Economic Recovery Transportation Electrification Plan (ERTAP). The plan is a requirement of Senate Bill 448 from the state legislature’s 2021 session.

NV Energy asked the commission to find that ERTAP satisfies the requirements of SB 448 and approve the utility’s proposed tariffs and rate schedules to implement the plan.

The three-year plan, which will start in 2022, will bring approximately 1,822 EV chargers to 120 sites throughout Nevada. (See NV Energy Proposes ‘Strategic Network’ of EV Chargers.)

The plan includes five programs as specified by SB 448.

Under the interstate corridor charging depot program, EV charging stations are planned for five sites, at locations yet to be determined, along Interstates 15 and 80 as well as U.S. 95.

An outdoor recreation and tourism program will add EV charging at ski resorts, casinos, convention centers, sports venues and other sites.

An urban charging depot program will bring an estimated 18 charging sites with a total of 180 charging ports to the Reno and Las Vegas areas.

The other two programs within ERTAP are a public agency EV charging program and a transit, school bus and transportation electrification custom program.

About half of the investments in the $100 million plan will be in or on behalf of historically underserved communities.

Environmental groups reacted positively to the plan’s approval.

Angie Dykema, the Southwest Energy Efficiency Project’s Nevada representative, said the plan may help lower Nevadans’ electric bills as widespread EV deployment brings more value to the electric grid.

“People will benefit from this plan even if they don’t drive,” Dykema said in a release.

Cameron Dyer, managing senior staff attorney for Western Resource Advocates, called the plan “a smart investment in Nevada’s future.” A recent study found that moving from gas-powered cars to EVs could bring $20 billion in economic benefits to the state, he said.

“This transition will also reduce air pollution, improve public health, protect the climate and make the electricity system more efficient,” Dyer said. “NV Energy’s investment in electric vehicle charging infrastructure is an important step to get more electric vehicles on our roads.”

December 2, 2021November 28, 2023

Vermont Climate Council Adopts ‘Initial Climate Action Plan’

In a 19-4 vote Wednesday, the Vermont Climate Council adopted what it is calling an “Initial Climate Action Plan,” with the expectation that it will update the plan next year.

Council members struggled with an aggressive timeline set by the 2020 Global Warming Solutions Act (GWSA) to bring its first action plan for Vermont to fruition by Dec. 1. In addition to noting that the plan does not fully meet the law’s objectives, the council acknowledged that the development process hindered its ability to ensure a just transition for all Vermonters as required.

“This Initial Climate Action Plan represents one of the first public processes in the state of Vermont to acknowledge and try purposefully to incorporate equity and the principles of a just transition in both its development and outcome — but we know we fell short,” the council said in an introductory letter to the plan.

Council Member Abbie Corse, of the Corse Farm Dairy, said after the vote that she does not believe the council had succeeded with the plan.

“I’m not fully comfortable voting yes for this plan, but [I voted yes] because I believe in the heart, the soul and the work and effort that was put forward by those people who have shown up day after day to try to make this happen,” she said.

The plan, according to Council Member Sue Minter, is “aspirational,” and she said that worries her. Minter is executive director of Capstone Community Action.

“Part of what worries me is the cost to already energy- and income-burdened Vermonters that this transition will incur,” she said. “But if we don’t set aspirational goals and trajectories, we won’t get there, and we need to keep moving and we need to get started.”

Council Member Jared Duval, executive director of Energy Action Network, expressed confidence in the plan.

“If the recommendations of the Climate Council as outlined in this plan are followed, not only do I think we can meet our legal requirements to reduce climate pollution, I am also confident that we can strengthen the Vermont economy while saving Vermonters money and helping to equitably transition away from dependence on imported high-cost and price-volatile fossil fuels,” he said.

The plan, he added, represents the “first serious attempt” by Vermont to “act at the scale and pace necessary” to address climate change in an equitable manner.

Council members will have the opportunity to provide dissenting statements for inclusion in the plan in the coming week. And this month, the council will meet to discuss public engagement on the new plan and how to relate actions in the plan to American Rescue Plan Act funding.

Major Initiatives

The plan’s recommendations focus on the following segments:

- - emissions reductions;
  - building resilience and adaptation in Vermont’s natural and working lands;
  - building resilience and adaptation in Vermont’s communities and built environment;
  - enhancing carbon sequestration and storage; and
  - cross-cutting pathways.

In total, the segments identify 26 pathways, 64 strategies and 230 steps for meeting the state’s emission-reduction requirements, according to the council.

Major initiatives recommended in the plan include:

- - adopting California’s Advanced Clean Cars II regulations beginning no later than model year 2026;
  - adopting California’s Advanced Clean Trucks Rule, Low NO_x Omnibus Rule and Phase II GHG Rule for Truck Trailers beginning no later than model year 2025;
  - joining the Transportation and Climate Initiative Program (TCI-P) when regional market viability exists (See Vt. Climate Council Adjusts Course on TCI-P.);
  - developing and implementing a multiyear, statewide Weatherization at Scale initiative to weatherize 90,000 homes by 2030;
  - instituting a rental property efficiency standard and setting a target for number of units to bring into compliance by 2030;
  - adopting legislation by May 2022 authorizing the Public Utility Commission to administer a Clean Heat Standard (See Vt. Climate Council Puts Clean Heat Standard on the Table.);
  - adopting a carbon-reduction policy directing the PUC to identify, review and research as needed design parameters for a 100% carbon-free or renewable electric portfolio standard no later than 2030 (See Negotiations Stall in GlobalFoundries’ Bid for Vt. Utility Status.);
  - adopting a Refrigerant Management Program to mitigate emissions from the industrial processes sector;
  - adopting rules to reduce emissions of high global warming potential gases in GlobalFoundries’ semiconductor manufacturing processes — pending the outcome of the company’s request for utility status (21-1107-PET); and
  - considering incentives for renewable energy generation siting in the built environment and penalties for siting renewables on intact ecosystems, forests and natural lands.

Sharp Criticism

Council members appointed by Gov. Phil Scott criticized the plan in a statement on Wednesday, saying it is “overly broad.”

“Climate change is real and accelerating,” the group said in the statement. “That said, no member of the administration supports the overzealous process established by the legislature in the GWSA nor each and every action in the Climate Action Plan issued today.”

Scott vetoed the GWSA in 2020, but the legislature overrode him. The council includes eight administration appointees and 15 legislative appointees. The four votes against adoption of the plan came from administration appointees.

“As the governor noted in his initial veto message, the act rightly should have committed to the executive branch the development and implementation of specific initiatives, programs and strategies to carry out legislative policy,” the group said. “Rather, the legislature created an unelected body, unaccountable to the voters, a majority of which are its own appointees to take on this executive function.”

The GWSA directs the Vermont Agency of Natural Resources to adopt rules that are consistent with the action plan by the end of next year to achieve the act’s 2025 emission-reduction requirements. If those rules are not adopted or emission reductions are not achieved, the GWSA allows anyone to sue the ANR secretary.

Many of the plan’s recommendations also will require legislative action to move them forward.

In its statement, the group highlighted the recommendation to join TCI-P as an effort that it argued would not have a successful outcome.

“We dissent from the majority decision to recommend that the General Assembly spend time and resources during the coming session to pass legislation so that Vermont is ‘ready to act swiftly and join TCI-P as a participating jurisdiction,’” the group said. Given the recent withdrawal of three states from the TCI-P, the council members believe the recommendation would “needlessly foreclose the consideration of alternatives to TCI that may prove more conducive.”

In the plan, the council emphasized the need for legislative action that authorizes a cap-and-invest-style program, “whether it’s TCI-P or a comparable approach.”

The council committed to identifying actions that can mitigate any gap in emissions reductions that would have been realized by TCI-P, with a target to adopt alternatives by June 2022.

Climate Advocates Respond

A group of climate advocates, which included Council Member Johanna Miller, energy and climate program director at the Vermont Natural Resources Council, applauded the council’s efforts in a statement.

Adopting the plan “is an important milestone,” Miller said. “At the same time, there is even more difficult work ahead to turn this plan into the bold, just climate action the intensifying climate crisis demands.”

While Ben Edgerly Walsh, climate and energy program director for Vermont Public Interest Research Group, said the plan “falls short in some ways,” he acknowledged that its “adoption lays the foundation for Vermont to finally treat this crisis with the seriousness it demands.”

Renewable Energy Vermont is encouraged that the council acknowledged the need to move to 100% renewable energy standard, but Executive Director Peter Sterling said “further action is needed.”

“Meeting Vermont’s energy and climate targets must be consistent with the principles of additionality laid out in both the Paris accords and the Global Warming Solutions Act,” he said in a statement. “And that should require 100% of Vermont’s electricity coming from renewable resources by 2030 with much higher requirements for newly built renewables than we have today, including at least 25% of that energy coming from clean, reliable and resilience-creating in-state renewable energy sources.”

December 2, 2021November 5, 2023

EJ Comm. Wants CARB GHG Plan to Cover Pesticides

Environmental groups have been urging the California Air Resources Board to include pesticide reduction strategies in its 2022 climate change scoping plan, and they now have the backing of CARB’s Environmental Justice Advisory Committee (EJAC).

The advisory committee voted on Nov. 9 to support a letter regarding pesticide use from Californians for Pesticide Reform and seven other groups.

As many as 59 organizations have signed onto letters to CARB or the governor this year asking that pesticide use be addressed in the 2022 scoping plan. The plan, which is updated every five years, is a roadmap for achieving the state’s greenhouse gas reduction goals.

And the groups made similar requests regarding pesticides during development of the 2017 scoping plan.

“Many of us have been calling for inclusion of pesticide reduction strategies in the state’s scoping plan since 2017, only to be told by CARB that there is insufficient research and/or that pesticides contribute only a negligible amount to GHG emissions when compared with other sources,” the groups said in their letter to EJAC.

The groups agreed that more research is needed on the subject of pesticides and greenhouse gases, and called for the state to fund studies on the topic.

But enough is known now to add pesticide reduction strategies to the scoping plan, they said. The groups have also asked CARB to add the Department of Pesticide Regulation to the list of 17 departments or agencies serving as collaborators on the scoping plan.

Pesticides’ Role Debated

EJAC was scheduled to hear an update from CARB staff on Nov. 16 regarding pesticides and the scoping plan, but the item was postponed. A CARB spokesperson did not respond to a request for comment on the letter the committee voted to support.

But CARB staff discussed pesticides during a July 20 scoping plan workshop focused on natural and working lands.

During the workshop, EJAC member Martha Dina Arguello asked how the impact of pesticides on greenhouse gas emissions would be addressed.

“I’m strongly concerned about excluding pesticides from the whole framing around the natural and working lands,” said Arguello, who is executive director of Physicians for Social Responsibility – Los Angeles.

Nicole Dolney, manager of CARB’s Emission Inventory and Economic Analysis Branch, said the agency is aware of two pesticides — methyl bromide and sulfuryl fluoride — that are greenhouse gases.

She said the use of methyl bromide is being phased out under the Montreal Protocol and emissions from the pesticide are “very small.” Sulfuryl fluoride is being tracked as part of the short-lived climate pollutants inventory, she added.

At least one study has found that use of sulfuryl fluoride is increasing as the pesticide replaces methyl bromide. The researchers, who describe sulfuryl fluoride as a potent greenhouse gas, found that the increase was mainly because of fumigation of buildings in North America. But postharvest treatment of crops also contributed, they said.

Matthew Botill, assistant chief of CARB’s Industrial Strategies Division, acknowledged the number of comments received on pesticides during the scoping plan process. Botill said pesticides weren’t directly included in modeling work discussed during the workshop.

“We are interested in looking at what those potential effects of pesticides are on greenhouse gas emissions,” Botill said.

GHG Contributions

In their letter to EJAC, the environmental groups outlined ways in which pesticides may contribute to greenhouse gas emissions.

The groups pointed to volatile organic compounds contained in pesticides, which react with sunlight and nitrogen oxides to form tropospheric ozone. Tropospheric, or ground-level ozone, is a greenhouse gas that is also harmful to health, according to the University Corporation for Atmospheric Research.

Soil fumigants, which account for about 20% of pesticides used in California, can increase nitrous oxide emissions, the groups said in their letter. In 2019, nitrous oxide accounted for about 7% of the nation’s greenhouse gas emissions from human activities, including agriculture, according to the U.S. Environmental Protection Agency.

In California, demographic data show “a pronounced racial disparity” in the amount of pesticide use in counties with the largest share of Latino residents, the letter said, with the greatest impact on the San Joaquin Valley.

In addition, the groups argue that organic farming naturally sequesters carbon and other GHGs to a greater extent than farming that uses chemicals.

“It is critical that the scoping plan include measures supporting rapid transition of chemical-reliant farming to organic farming that focuses on building soil and plant health,” the groups said.

December 2, 2021

MISO Modifies Stakeholder Meeting Schedule

MISO has scrapped its plan for a meeting schedule that would have packed all major stakeholder meetings into a single week eight times per year.

Instead, the grid operator will stagger eight meetings of its main stakeholder committees across the year, alternating between in-person and virtual formats. The modified schedule still will have MISO holding fewer stakeholder meetings throughout the year.

The RTO said in September that it planned to squeeze all stakeholder meetings of its main parent entities into eight separate weeks over the year, creating “superweeks” consisting of all-day meetings. The new calendar was to take effect next year. (See MISO Wants Abridged Stakeholder Meeting Schedule.)

MISO defines its main parent entities as the Market Subcommittee (MSC), Resource Adequacy Subcommittee (RASC), Reliability Subcommittee, Planning Advisory Committee, and Regional Expansion Criteria and Benefits Working Group, which makes cost-allocation decisions. The committees currently meet monthly in separate weeks dubbed as planning week, markets week and reliability week.

The grid operator’s head of stakeholder relations, Bob Kuzman, said the new schedule will allow MISO to preserve its markets week and planning week.

“We heard your feedback, and we made a lot of changes to the proposal,” he told stakeholders during Wednesday’s RASC teleconference. “We heard that superweeks were going to provide too much information for stakeholders to digest.”

In response, the RASC and MSC only approved the first five months of their 2022 meeting dates. The committees usually set a full calendar year of meetings during their December meetings.

RASC Chair Chris Plante said committee chairs will still have to make sure their workplans and goals will be able to fit into the new calendar.

Speaking on behalf of his company, WEC Energy Group, Plante said he was willing to give the new meeting frequency a try.

MISO client relations staff had framed the new meeting schedule as a transition to in-person meetings after two years of pandemic-induced isolation.

Kuzman said MISO will review the schedule with stakeholders in May to gauge its effectiveness. “This allows the face-to-face meetings as we get back to an in-person schedule.”

He also said the new schedule will give staff subject matter experts respite between meetings to ready discussion points and meaningfully tweak proposals based on stakeholders’ suggestions.

“MISO can get a little bit better prepared for the meetings, with better material and better answers to stakeholders’ questions,” Kuzman said.

The RTO had said the meetings’ monthly pace was leaving staff in a cycle of preparing and delivering presentations, sometimes reciting information from identical slides across different committees.

The grid operator’s first vision for pared-down in-person meetings proved unpopular with stakeholders.

In November, Plante said MISO should have consulted with stakeholder committee chairs to determine whether the groups could cover 12 months of agenda items across just eight meetings a year.

Plante also said there was probably a better way of limiting COVID-19 exposure between stakeholders and MISO staff. MISO said fewer in-person meetings might lessen the chances that someone contracts the coronavirus.

“I would have much rather seen us maintain the monthly meetings with an in-person meeting every other month,” Plante said during a Nov. 4 MSC meeting.

“We were not approached about whether this would have been a good thing,” MSC Chair Megan Wisersky said. “I’m concerned there wasn’t enough stakeholder discussion outside of the Advisory Committee.”

Wisersky also questioned whether the schedule should be provisional, adding that, “sometimes when MISO suggests something is temporary, it often becomes permanent.”

Multiple stakeholders have also said change will relieve the pressure on staff to appear monthly and present market changes.

Wisersky, speaking as a representative of Madison Gas and Electric and not as a subcommittee chair, said she hoped MISO wasn’t using the COVID-19 pandemic as a “guise” to disrupt the stakeholder process.

“It’s not practical for us to block off an entire week for MISO meetings,” WPPI Energy economist Valy Goepfrich said.

Kuzman has asked stakeholders to be patient while the RTO navigates a return to in-person meetings.

“We’ve all been separate.” Kuzman said. “We miss the coffee talk; we miss the lunch talk.”

December 2, 2021

MISO Market Subcommittee Briefs: Dec. 1, 2021

Stakeholders Surprised at Integrated Roadmap Changes

MISO plans to revise its Integrated Roadmap process, the ongoing five-year workplan that prioritizes and tracks progress on market improvements.

The grid operator is doing away with a stakeholder ranking of improvements. Additionally, it will now accept suggestions for improvements on RTO operations year-round instead of imposing an annual deadline. MISO usually closes a submission window late in the year and begins prioritizing issues early the following year.

Stakeholders attending Wednesday’s Market Subcommittee meeting said they weren’t notified that MISO would change the process so dramatically. They said staff should have approached them during earlier subcommittee meetings to discuss the change before their announcement.

MISO’s head of stakeholder relations, Bob Kuzman, said executives will deliver a more in-depth briefing on the changes during next week’s Board Week.

Low Numbers for New Member Interface

MISO customers are slowly migrating to the new market user interface. Only 24 of 294 customers have fully migrated to the new system, with another 86 in the process.

“We are making very slow progress towards the migration,” said Arijit Bhowmik, MISO director of real-time applications.

The RTO’s revamp of is market interface ― where participants submit bids and offers ― is part of its market platform replacement.

MISO will retire its legacy system on Jan. 18. It began a four-month parallel operations phase on Sept. 8.

MISO’s short-term reserve product, which is set to go live on Tuesday, relies on the new market user interface. Short-term reserves are meant to supply energy within 30 minutes.

MISO: Member Privacy Trumps Zonal Data Sharing

In responding to stakeholders’ requests for access to seven-day load forecasts in their local balancing authority or resource zones, staff said they could publish weekly load forecasting data, but only on a subregional basis.

MISO’s Congcong Wang said the RTO has a few local BAs that rely on just one or two suppliers. Divulging load data for those areas would display confidential information, she said.

Wang said staff can share its load data broken down to MISO South and the North and Central portions of MISO Midwest.

Some customers have asked for access to seven-day load forecasting data at the local BA or local resource-zone levels. (See “Tx Customers Ask for Additional Load-forecasting Data,” MISO Market Subcommittee Briefs: Oct. 7, 2021.)

Most RTOs make load forecasting data for the coming week available to their members, though the level of detail varies.