Search
`
November 5, 2024

FERC Approves $156K WECC Penalties

FERC last week approved WECC-levied penalties totaling $156,000 against Black Hills Power (NYSE:BHP) and Southern California Edison (NYSE:EIX) for violations of NERC reliability standards (NP22-3).

NERC submitted the settlements to FERC on Oct. 28 in a spreadsheet Notice of Penalty. The commission indicated last week it would not review the WECC settlements, along with a separate $300,000 penalty against Ohio Valley Electric Corp. (See OVEC Hit with $300K in NERC Penalties.)

BHP Reports Study Shortfalls

Black Hills’ $46,000 penalty resulted from three violations of TPL-001-4 (Transmission system planning performance requirements) and one each of PRC-005-1 (Transmission and generation protection system maintenance and testing) and PRC-005-6 (Protection system, automatic reclosing, and sudden pressure relaying maintenance). All were self-reported.

The utility’s infringement of TPL-001-4 had to do with the 2017 and 2018 Transmission Coordinating Planning Committee (TCPC) studies, which Black Hills discovered in 2020 had not been completed to requirements R2, R3 and R4 of the standard. Specifically, several aspects of the planning assessment were not finished in 2017 because the employees who were assigned to handle those parts left the company before it was done. The following year’s assessment was completed late as well, though WECC did not state whether this was because of the employees’ departure as well.

WECC assessed the risk level of the violation as minimal and acknowledged that it “did not pose a serious or substantial risk to the reliability of the bulk power system.” However, the regional entity also pointed out that the lack of a complete planning assessment could have limited Black Hills’ ability to “identify weaknesses in its system … implement action plans for identified system deficiencies or make needed system improvements.”

The RE regarded the issues with Black Hills’ planning assessments as systemic, warranting a financial penalty, because of the number of requirements violated and the fact that they spanned several years. The utility’s first mitigating action for the infraction was to complete the missing aspects of the affected assessments, which it did in 2020 while working on the 2019 assessment. It also created a TPL-001-4 process checklist to monitor the project’s progress each year, with backup plans for what to do if the needed information is not available in time.

The PRC-005-1 violation originated with Black Hills’ failure to verify the functioning of battery terminal connection resistance and battery interval or unit-to-unit connection resistance in two battery banks at a 230-kV converter substation. Black Hills reported in 2019 that it had not performed the testing — which is required every 15 months, according to the standard — since the standard became effective in 2007 because contractors performing the testing were unable to access the battery’s posts and straps. Black Hills verified the resistance of the batteries and replaced the bolts that kept contractors from accessing the batteries.

Similarly, the utility’s violation of PRC-005-6 was failure to verify that the communications system at a bulk electric system substation was functional every four calendar months. Black Hills found that its internal BES review committee “did not analyze and recategorize the substation as containing BES elements” after a new substation was interconnected on the BHP system in 2016. The utility completed the required maintenance testing, conducted an extent of condition review that found no other instances of noncompliance, and overhauled its BES review committee.

WECC considered these infractions systemic as well because of the overlapping timelines. The RE noted Black Hills’ internal compliance program but did not consider it a mitigating factor because of its failure to detect or prevent these violations, as well as the violations of TPL-001-4.

Testing Failures Net $110K Penalty for SCE

The $110,000 penalty for SCE originated from a violation of regional reliability standards FAC-501-WECC-2 (Transmission maintenance) and FAC-501-WECC-1, the earlier version replaced by FAC-501-WECC-2 in 2018.

SCE reported both infractions in May 2019. The utility discovered the infringement of FAC-501-WECC-2 first: It realized that three series capacitors and three circuit breakers that were elements of major WECC transfer paths had not been maintained and inspected in January 2019 as the standard required. The second violation was discovered during the investigation of the first, when SCE found that it did not have documentation of the 2016 and 2017 reviews of its transmission maintenance and inspection program (TMIP). The utility was also late in completing the 2018 TMIP review.

WECC found that the root cause of the original violation was failure to track the progress of the inspections, coupled with lack of communication between responsible parties. The second was caused by poorly defined management policy guidance and expectations, specifically the lack of a formal process for initiating the annual review of the TMIP, for documenting its completion or for storing the documents.

SCE mitigated the infractions by completing maintenance and testing for the series capacitors and circuit breakers, updating its monthly workload planning checklist to ensure the TMIP is completed, and documenting the scheduling process project plan. It also documented a process for annual review of the TMIP.

Nevada Gov. Sisolak Appoints Regional Transmission Task Force

Nevada Gov. Steve Sisolak on Thursday announced the membership of a panel that will advise the governor and legislature on potentially bringing the state into an RTO.

Formation of the Regional Transmission Coordination Task Force is a mandate of Senate Bill 448, a wide-ranging energy bill that Sisolak, a Democrat, signed into law on June 10. (See Many Next Steps to Follow Passage of Nevada Energy Bill.)

Sisolak named Sen. Chris Brooks (D), the bill’s author, as chairman of the task force. Its other 18 members include representatives of utilities, labor, environmental groups, business and government.

The governor’s office expects to add five more task force members in coming weeks.

“This task force will further advance our state’s mission of developing our infrastructure, bolstering our commitment to renewable energy and building out our green energy economy,” Sisolak said in a release.

RTO by 2030

SB 448 includes a requirement for transmission providers to join an RTO by January 2030, unless they can show that they haven’t been able to find a viable RTO or that joining an RTO wouldn’t be in the best interest of the providers or their customers.

The Regional Transmission Coordination Task Force will formulate advice on topics and policies related to regional energy transmission in the West.

Under the provisions of SB 448, the task force will study the potential costs and benefits of forming or joining an RTO, for transmission providers and their customers in Nevada. The task force may bring in an independent third party to help analyze those costs and benefits.

The panel will explore policies to help bring transmission providers in the state into an RTO by 2030, including whether any legislation is needed to allow the providers to join an RTO.

The task force will also look at business the state could attract by having a position in a regional wholesale electricity market. It will look at locations for new transmission facilities that would help achieve the state’s clean energy and economic development goals.

The task force will meet at least twice a year and send a report to the governor and legislature by Nov. 30, 2022, ahead of the state’s 2023 Legislative session.

Cost Savings, Reliability

Western Resource Advocates, which has a representative on the task force, pointed to a market study this year that found Western electricity customers could save more than $2 billion a year if a single market operator managed transmission and coordinated generation planning. Such a move could also support renewable energy development and improve reliability. (See Study Shows RTO Could Save West $2B Yearly by 2030.)

“The state task force’s work on a Western regional transmission organization will help Nevada reap the economic, environmental and reliability benefits of regionalization,” Vijay Satyal, Western Resource Advocates’ regional energy markets manager, said in a release.

Members of the Regional Transmission Coordination Task Force are:

      • Sen. Chris Brooks (chairman)
      • David Bobzien, director, Governor’s Office of Energy
      • Kris Sanchez, deputy director, Governor’s Office of Economic Development
      • Carolyn Barbash, vice president, transmission development and policy, NV Energy
      • Carolyn Turner, executive director, Nevada Rural Electric Association
      • Cameron Dyer, managing senior staff attorney, Western Resource Advocates
      • Eric Witkoski, executive director, Colorado River Commission of Nevada
      • Erik Hansen, chief sustainability officer, Wynn Resorts
      • Jeremy Newman, assistant business manager, IBEW Local Union 396
      • Leslie Mujica, executive director, IBEW/NECA/LMCC – Las Vegas Power Professionals
      • Luke Papez, director, project development, LS Power Development
      • Richard Perkins, president/CEO, The Perkins Co.
      • Mona Tierney-Lloyd, head, U.S. state public policy and institutional affairs, Enel North America
      • Samuel Castor, EVP of policy, Switch
      • John Seeliger, regional energy manager, Nevada Gold Mines
      • Kostan Lathouris, managing member, Lathouris Law PLLC
      • Rebecca Wagner, owner/consultant, Wagner Strategies
      • Elizabeth Becker, FEMA, Local Hire – emergency management specialist
      • Hayley Williamson, chair, Public Utilities Commission of Nevada

New York Using Multitude of Strategies to Clean up Transit

From Buffalo to Long Island, New York is trying to reduce transportation-related pollution not only by promoting electric vehicles, but by increasing the availability of public buses and light rail, developing greenways to make bicycling safer and easier.

Betta-Broad-(NYCP)-Content.jpgBetta Broad, NYCP | NYCP

“The regional Transportation and Climate Initiative Program (TCI-P) had some setbacks, but we’re still committed to the program and want people to take action by supporting it and signing our petition to send a message to Gov. [Kathy] Hochul,” Betta Broad, director of New Yorkers for Clean Power (NYCP) and a member of the state’s Climate Action Council, said Wednesday as she hosted a “teach-in” on clean transportation on behalf of NY for TCI.

Connecticut Gov. Ned Lamont, Massachusetts Gov. Charlie Baker and Rhode Island Gov. Dan McKee separately announced last month that their states would back away from the program, which they and D.C. in December 2020 had signed a memorandum of understanding to join. (See Conn. Environmental Advocates Urge Continued Commitment to TCI-P.)

“We hope to see TCI included in the Climate Action Council’s plan that will also be circulating across the state next year, with lots of opportunities for public comment,” Broad said.

EVs vs. Mass Transit?

Meanwhile, passage of the bipartisan infrastructure bill in Washington means many billions of dollars coming to New York for transportation initiatives, she said.

Douglas Funke, president of the city’s Citizens for Regional Transit, said investing in more infrastructure to accommodate individual vehicles is not the ideal solution.

“We really have to fix the car problem, and public transit in our opinion is the way to do that,” Funke said.

He noted that Buffalo had a plan for a 42-mile light rail network but only built 6 miles. The city is building another 6, which is encouraging, he said, but it’s still far from the goal.

Changing all vehicles to electric doesn’t work in urban areas like Buffalo or New York City, Funke said, “because you still have the congestion, still have all the parking, all the roads. Every ton of concrete generates a ton of CO2, so if you have to keep building parking lots and roads and repairing them for all the cars, it just creates more pollution.”

Mariah-Okrongly-(NYCP)-Content.jpgMariah Okrongly, Bedford 2030 | NYCP

In suburban Westchester County, however, EVs make more sense, said Mariah Okrongly, program manager at Bedford 2030, which is working to get local school districts to buy electric school buses.

Her organization expects at least one of the school districts in the next bond proposition to include an electric school bus, but it has been difficult selling the novel concept of using the buses to feed the grid with the vehicle-to-grid technology, Okrongly said.

“So it definitely is a long a long-haul initiative, but worthwhile, and with the new infrastructure bill and all the funds associated with that, there’s going to be a bigger push to move forward with this, so I think it’s a prime time if you’re considering this to begin the process,” Okrongly said.

Another town, Peekskill, is hosting a pilot on-demand, fully electric transit program that links with Westchester’s Bee-Line bus network, said Nina Orville of Sustainable Westchester.

The on-demand fleet also provides the opportunity to build out the charging infrastructure in Peekskill, where most households have either one car or none, Orville said.

“We still need to do work across the state to address tariffs for charging vehicles, which is particularly important for people who live in multifamily housing and have to use charging infrastructure that might be billed different rates than if they had their own charging equipment,” she said.

On-demand EVs “would be swell” in southeast Queens, where most commuters still have to take a bus to a Long Island Rail Road station and then to the New York City Subway to get to work, said Jean Sassine, a member of New York Community for Change.

“We just need more buses, more electric buses because … most of the pollution is coming from cars,” Sassine said. “Queens is built with the idea of that old sprawl mentality, so we’re either driving or waiting for buses.”

Greenways Connect People

Ibrahim-Abdul-Matin-(NYCP)-Content.jpgIbrahim Abdul-Matin, Green Squash | NYCP

The Brooklyn-Queens Greenway is part of a larger effort to develop dedicated biking and walking paths throughout New York City, said Ibrahim Abdul-Matin, of consultancy Green Squash, who also serves on the state’s advisory board of the Trust for Public Land.

A lot of people don’t necessarily feel safe or comfortable on the subway or they live far from where they work, Abdul-Matin said. The old purpose of greenways was to infuse residents with trees and wildlife, but now the idea is to reconnect and create a whole different type of transportation infrastructure, he said.

The Trust for Public Land has put together a slate of projects to help conserve and protect natural areas around the country, and almost every initiative had bipartisan support, he said.

Brigitte-Griswold-(NYCP)-Content.jpgBrigitte Griswold, Groundwork Hudson Valley | NYCP

Community volunteers in Yonkers thought they were doing trash pick-up on a series of vacant lots, but then realized the lots were the former route of an abandoned railroad known as the Putnam that used to run from New York City all the way up to Brewster before it was discontinued in the 1940s, said Brigitte Griswold, executive director of Groundwork Hudson Valley.

“A piece of the old railroad was completely forgotten: a 2.2-mile route that was a spur off the main line that ran from New York City to downtown Yonkers,” she said. “And so we got involved with thinking about how we could convert these series of vacant lots into a green bike and walking pathway.”

The Yonkers Greenway wasn’t originally conceived as a green solution, but as an answer to crime and a way to revitalize economic activity in the neighborhoods where businesses were shuttered, she said. When completed within the next two years, the greenway will be a 15-minute bike ride to Manhattan and will also connect with the 242nd St. subway stop in the Bronx.

Yonkers-Greenway-(NYCP)-Content.jpgFor over 12 years Sustainable Westchester has been developing the Yonkers Greenway to transform a disused railway into a green corridor to Manhattan. | NYCP

Meanwhile, the Center for Post Carbon Logistics is developing solar-powered boats to carry freight up and down the Hudson River, said Andy Willner, the center’s executive director.

“The schooner Apollonia is a freight sailing vessel that carries Hudson Valley goods to and from New York City,” Willner said. “Primarily their cargo has been grains and malted barley for beer and distilled spirits, but they also had their first interaction with a cross-oceanic sailing vessel.”

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.

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.”

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.

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.

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-(NYDPS)-Content.jpgPhilip 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-(NYDPS)-Content.jpgCarl 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.

Bob-Howarth-(NYDPS)-Content.jpgRobert 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.

Gavin-Donohue-(NYDPS)-Content.jpgIPPNY 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

Doreen-Harris-(NYDPS)-Content.jpgNYSERDA 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.jpgThe 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.”

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.”

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 NOx 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.”