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November 14, 2024

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SPP’s Stakeholder Process Attracts Markets+ Participants

TEMPE, Ariz. — While other Western Interconnection entities have spent their time recently filing comments on the SPP Markets+ tariff or committing to CAISO’s competing Extended Day-Ahead Market (EDAM), participants in SPP’s day-ahead proposal gathered in the Desert Southwest on April 30 for a healthy dose of the RTO’s stakeholder process. 

SPP has long prided itself on that process, which seeks membership’s consensus before any consideration for approval. Staff will tell you stakeholder-driven is not just a slogan, but reality. 

“Our specialty has always been in the stakeholder process. By bringing a lot of those best practices from our experiences and expertise in the East to the West, we’ve shaped it to help facilitate progress with the stakeholders here,” said Carrie Simpson, SPP’s Denver-based director of seams and western services. 

Shielded from Tempe’s bright sun and springtime heat by Salt River Project’s cavernous PERA Training & Conference Center, attendees dug into how they can submit tariff and governing revision modifications and interact with SPP staff. 

Senior market analyst Kristen Darden detailed the background, forms, structure and steps within the Markets+ revision request (MRR) process. Modeled after SPP’s RTO process, it facilitates stakeholder input and discussion by providing a transparent method for stakeholders and staff to recommend additions, deletions or changes to Markets+’ governing language.  

MRRs will be submitted through SPP’s Request Management System, an online platform that hosts the revision request process and responds to general questions, inquiries and requests. It also contains a knowledge base that can be used for FAQs.  

Once MRRs are posted to SPP’s website, they are open to comments. 

“I get really excited about our program,” Darden said. “I think it’s a great feature that we have. It shows we are stakeholder driven, we are considered public or transparent with everything that we do.” 

“I think they have embraced it, and it wouldn’t be successful without them embracing it and digging into it and participating,” Simpson said. “We’ve got diverse parties, different sectors, different regions of the West, and I absolutely think that’s been a part of the success of Markets+.” 

As if to drive the point home, SPP staff agreed with the Markets+ Participants Executive Committee (MPEC) that more education and input is needed on managing transactions across the market’s seams with EDAM and other balancing authority areas. Of course, SPP has deep experience in this area, given its seams with MISO. 

“It’s not a secret to anyone that the biggest scenario around objection to Markets+ is the seam,” said MPEC Chair Laura Trolese, with The Energy Authority. “I think starting to work through where the tension points are and what we can do to reduce transactional friction, I think would behoove us to be doing that work earlier rather than waiting till the end of the year.” 

“As staff, we hear loud and clear that we want to figure this out,” Simpson said. “I think there’s still just confusion on how it works if we do nothing, and so I think starting there can help people identify what friction exists and what friction does not exist. It’s a very important issue to address, and so I think we let that [stakeholder] process play out.” 

For the time being, “transactional friction” will go into the parking lot of items to be addressed further, but with a high priority. 

MSC Concerns on Tariff

Arizona Corporation Commissioner Nick Myers, incoming chair of the Markets+ State Committee (MSC), said that while the “industry” has said the tariff is good to file at FERC, some state regulators are concerned about market participants opting-out transmission capability from the market. 

“Some states have said they see that as a dealbreaker,” he said. “We’re still trying to strive for some consensus on that.” 

In comments filed at FERC, the MSC said some members have “strong concerns about the lack of guardrails around the monthly opt-out provision.” The tariff allows market participants to opt out with only 15 days’ notice. (ER24-1658). 

“It is critical to specify these reasons to safeguard against potential market manipulation,” the committee wrote. “It is unclear to the MSC how this option will operate in the context of reliance on the [Western Resource Adequacy Program]’s transmission requirements to ensure resource sufficiency in the day-ahead and real-time markets.” 

The Markets+ tariff requires its participants to also take part in the WRAP. That integration was cited by Bonneville Power Administration staff in their recommendation that the federal power marketing administration choose the SPP-run market over CAISO’s. (See BPA Staff Recommends Markets+ over EDAM.)  

“[It’s] about what constitutes the reasoning behind opting out,” Myers said. “There could be situations where that transmission is needed for other parties, and now there could be market advantages to an entity pulling out some transmission for no other reason than their own market advantage. There needs to be bounds around when that’s allowed to happen.” 

SPP said it “fully expects” the tariffs of participating Markets+ transmission providers and balancing authorities to have more details on opt-outs and promised to provide further details on the provision. 

“More transmission is better than less,” SPP attorney Chris Nolen said. “The opt-out gives us the ability to have transmission participate in the market. [Some entities] may have seasonal limitations or other things that absent some ability to opt out and we might not have access to that transmission at all.” 

Alluding to temperatures that would hit 96 degrees Fahrenheit during the meeting, Myers told MPEC attendees to count their blessings. “You guys are lucky it still hasn’t hit 100 degrees yet here in Arizona,” he said. 

Myers and Vice Chair John Hammond, with the Idaho Public Utilities Commission, are replacing Colorado’s Eric Blank and Oregon’s Letha Tawney, respectively.  

The MSC comprises regulators from Arizona, California, Colorado, Idaho, Montana, Nebraska, Nevada, New Mexico, Oregon, South Dakota, Utah, Washington and Wyoming. 

APS’ Walter Joins MPEC Leadership

New MPEC Vice Chair Kent Walter, Arizona Public Service | © RTO Insider LLC

The MPEC approved Arizona Public Service’s Kent Walter’s nomination as committee vice chair, replacing co-worker Brian Cole. Trolese remains as MPEC chair. 

The committee endorsed an interim governance task force that will initially have to solicit leadership nominations. It either will report back to MPEC during its August meeting in Colorado or seek approval of its chair with email votes. The task force then will draft language setting requirements on stakeholder group attendance, proxies and absences. 

MPEC also approved Chelan County (Wash.) Public Utility District’s Steven Wickel to a public power seat on the Markets+ Transmission Working Group. Seven other vacancies remain on various stakeholder groups.

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Eversource Announces $500M Cut in Connecticut Investments

Eversource Energy will reduce its investments in Connecticut by about $500 million over the next five years because of the “negative regulatory environment” at the Public Utilities Regulatory Authority (PURA), executives told investors during the company’s first-quarter earnings call May 2. 

“As it stands, regulatory policies in Connecticut discourage investment and utility innovation, as well as our participation in a wide range of clean energy initiatives that rely on our balance sheet,” Eversource CEO Joe Nolan said. 

The PURA has deferred and delayed cost recovery on Eversource’s investments, Nolan continued. The company is also pursuing a legal challenge of a rate cut imposed on its water utility subsidiary. 

“Without recognition that our funding sources rely on a secure and predictable cost-recovery path, we cannot move forward to put additional capital resources on the table,” Nolan said.  

CFO John Moreira added that the company is unwilling “to put capital at risk in relation to advanced metering infrastructure and electric vehicle programs” and is planning to cut spending in the state by nearly $100 million in 2024. But he emphasized that Eversource’s overall forecasted expenditures across its entire system has not changed. 

“Emerging infrastructure needs across our system provide ample opportunity for capital deployment in lieu of using those valuable resources in Connecticut,” Moreira said. 

Following Eversource’s announcement, Connecticut Gov. Ned Lamont (D) bluntly told The Connecticut Mirror he would reappoint PURA Chair Marissa Gillett, whose term ended March 1. 

During Gillett’s time at the PURA, the agency has frequently drawn the ire of Eversource and Avangrid. Lamont has indicated that the companies have pushed for her ouster. 

Gillett has been a proponent of performance-based regulation, and the PURA imposed significant fines on Eversource for poor performance in 2020 during Tropical Storm Isaias and for declining to disclose if it used ratepayer funds to promote new natural gas hookups. 

In an interview with David Roberts on his podcast “Volts” in January, Gillett expressed her intent to make utility profits more dependent on their performance in helping to meet the state’s reliability, affordability and climate priorities. 

“What the fight is in our dockets right now is whether the [performance-based regulation] incentive mechanisms are layered on top of an authorized [return on equity] or whether they’re a component of the ROE,” Gillett said. 

A PURA spokesperson did not respond to RTO Insider’s requests for comment in time for publication, but a spokesperson for Lamont said “Eversource has a legal obligation to maintain grid reliability, and we are confident they will uphold that commitment.” 

Offshore Wind, NH Solar

Eversource also provided an update on its exit from the offshore wind sector, saying it is nearing the completion of the sale of its stake in South Fork Wind and Revolution Wind to Global Infrastructure Partners, and Sunrise Wind to Ørsted. 

“We are on track to close the sale of the three projects over the coming months,” Nolan said. “We are progressing well on the approvals necessary to close these transactions.” 

Eversource anticipates that the cash proceeds from the sale to GIP will total $1.1 billion, Moreira said. 

Nolan noted that onshore and offshore construction has begun on the Revolution Wind project but declined to specify further details on the progress. 

“Now that our offshore wind risk is largely behind us, we are very excited about the future of Eversource, delivering safe and reliable electric, natural gas and water service to our 4.4 million customers,” Nolan said. 

Eversource is also discussing the potential for new investments in solar in New Hampshire, he said. 

“We will likely be proposing an investment opportunity in the months to come,” he added, while highlighting ongoing efforts by the New Hampshire legislature to revamp the state’s Site Evaluation Committee and accelerate permitting and siting processes. 

Nolan said he is encouraged by the state’s interest in utility-owned solar and that the significant amount of land available close to Eversource’s power infrastructure creates a “great opportunity” for investment. 

Eversource reported net income of $521.8 million ($1.49/share) for the first quarter, up 6.2% over the same period last year. 

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NEPOOL Participants Committee Briefs: May 3, 2024

Order 2023-A Compliance Proposal Approved

The NEPOOL Participants Committee approved ISO-NE’s Order 2023-A compliance proposal May 3, making incremental changes to its previous plan approved in March. (See NEPOOL PC Backs ISO-NE Tariff Revisions for Order 2023 Compliance.) 

Order 2023-A “did not necessitate major changes to the Order No. 2023 compliance proposal that the Participants Committee unanimously supported at its March 7 meeting, and most of the proposed incremental changes are in the nature of specific clarifying revisions,” ISO-NE noted. 

The RTO said it is planning to submit two compliance filings for the order by May 14. 

COO Report

ISO-NE COO Vamsi Chadalavada reported that the system peaked in April at 15,657 MW and also reached its lowest load level in recent years, about 6,600 MW. 

The low load levels were caused largely by the continued growth of behind-the-meter solar, which grew in the region by just under 1,100 MW over the past year, Chadalavada said. 

He added that he expects similar rates of growth over the next seven to 10 years, which will likely continue to lower energy prices during peak solar hours and incentivize more battery storage to come online. 

Overall energy market value was about 30% lower than April 2023 as gas prices trended down, Chadalavada said. Imports were significantly reduced because of drought conditions in Québec, he added. 

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Southern Credits Strong Southeast Economy for Earnings Growth

Southern Co.’s financial performance has continued to improve on the back of strong economic growth in Georgia and other Southern states, executives said in an earnings call May 2. 

The company’s businesses “experienced a strong start” in the first quarter of 2024, CFO Dan Tucker said, with Southern reporting an overall net income of $1.13 billion through March 31, up from $862 million for the same period last year. Earnings per share for the quarter stood at $1.03, 13 cents above the company’s estimate and 24 cents higher than the first quarter of 2023. 

The company reported total operating revenue of $6.65 billion, compared to $6.48 billion in the first quarter of 2023, with operating expenses of $4.94 billion, down from $5.26 billion last year.  

Among the factors contributing to income growth, Tucker highlighted stronger-than-expected electricity sales to commercial customers in general and data centers in particular, with revenue from the latter category growing more than 12% in the quarter. Retail electric sales to all classes of customers were up 1.7% from the first quarter of 2023, Tucker said, while industrial sales grew only 0.4% but were “beginning to show signs of recovery following a soft 2023,” with increased revenue from the lumber and paper industries. 

The CFO pointed to the average unemployment rate of 3% across the company’s electric territories and said strong growth is likely to continue, with “a favorable business climate and increased expansion of manufacturing … attracting new households to the Southeast.”  

CEO Chris Womack called the company’s performance “a testament to our team’s collective commitment to serving customers reliably across our business.” He said Southern is “positioned as well or better than any utility company in the country” to continue improving. 

Womack also applauded the end of the “at-times … arduous journey” of constructing units 3 and 4 at the nuclear-powered Plant Vogtle, operated by Southern subsidiary Georgia Power near Waynesboro, Ga. Work on the new reactors wrapped up just days before the call with Unit 4 entering commercial operation on April 29, while Unit 3 did so on July 31, 2023. (See Southern Looks Beyond Vogtle After Challenging 2023.) 

Construction began on units 3 and 4 in 2009, with both originally intended to be operational by 2017. The company has called the reactors the first nuclear generators built in the U.S. in 30 years. However, the project underwent numerous delays and cost overruns, with some observers estimating a final bill of $35 billion, around $21 billion over the initial budget.  

“I cannot be prouder of our team’s perseverance and commitment to getting Vogtle units 3 and 4 completed with the standard of quality fully demonstrated by Unit 3’s performance since it [entered] service last July,” Womack said. “Success on this historic project required the hard work and dedication of tens of thousands of American craft workers and engineers, a committed group of co-owners, and regulators who had the courage to support nuclear when others did not.” 

Womack said completion of the plant was proof “that new nuclear is achievable in the United States [to meet] ever-increasing demands for carbon-free energy … to support our digital economy and society.”  

The CEO expanded on the need for nuclear energy later in the call, saying that “no technology is better suited” for the economy’s needs. At the same time, he admitted that in light of the delays and budget issues at Vogtle, it would likely be “a very long time” before Southern attempts more nuclear construction, and called on the federal government to “provide great leadership” to sway the industry to build more reactors. 

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Exelon Focuses on ComEd, Other Rate Cases in Q1 Earnings Call

Exelon CEO Calvin Butler opened the company’s first-quarter earnings call May 2 with a tribute to his predecessor, Chris Crane, who died April 13, then quickly turned to the business at hand: the rate cases, from Illinois to D.C., that could have major impacts on the utility’s bottom line and profitability. 

“A key goal this year is to improve our regulatory outlook in Illinois,” Butler said, referring to the Illinois Commerce Commission’s rejection of Commonwealth Edison’s integrated grid plan Dec. 14 for failing to meet core provisions of the state’s Climate and Equitable Jobs Act.  

The ICC sent both ComEd and Ameren Illinois back to the drawing board after finding the utilities had not sufficiently incorporated customer affordability into their plans or outlined how 40% of plan benefits would go to low-income and environmental justice communities, “among other shortcomings,” according to the commission’s announcement. 

With a 90-day deadline for submitting a revised plan, “the ComEd team got to work the day after the order and worked tirelessly with key stakeholders … to create an updated plan that … is thoroughly responsive to the ICC’s direction,” Butler said. 

“We outlined in detail, for every customer and community, [the] benefits from the clean energy transition,” as well as providing an affordability analysis, CFO Jeanne Jones said. “Specifically, through focused grid investments in disadvantaged communities, more than 40% of the benefits of grid modernization and clean energy have been demonstrated to support equity-investment-eligible communities’ customers.” 

The revised plan was submitted March 13, Butler reported. The ICC has scheduled intervenor testimony, rebuttal and an evidentiary hearing in May, June and August, respectively, with a final decision expected in December. 

Jones also provided a rundown of recently approved and pending rate cases across Exelon’s utilities, beginning with the Delaware Public Service Commission’s approval April 18 of a settlement in Delmarva Power’s rate case, allowing a $27.8 million increase in the utility’s revenue request. 

Pending regulatory approvals include multiyear rate cases for Pepco in both D.C. and Maryland, with decisions expected this summer or early fall, and PECO Energy oil and gas rate cases in Pennsylvania, expected in either November or December. 

Data Centers in Pa.?

Exelon’s earnings edged down in the first quarter of 2024 compared to the year before, Jones said. The company’s non-GAAP net income was $685 million ($0.68/share), versus $696 million ($0.70/share) for the same period in 2023. Corresponding GAAP figures were $658 million net income ($0.66/share) for Q1 2024 and $669 million net income ($0.67/share) in 2023. 

Butler pointed to the combination of a warmer-than-normal winter and severe storms as factors in the decrease. Jones also cited higher costs from storm damage, as well as high interest rates and higher levels of debt at both the company and its utilities. 

With data centers and the resulting demand growth exploding across the country, Aidan Kelly, an analyst with J.P. Morgan Securities, asked if Pennsylvania might be a prime candidate for data center development, with its large natural gas reserves at the Marcellus and Utica shales. 

“The short answer is ‘yes,’” Butler said. “And I would tell you that we continue to see significant activity around high-density load growth in general,” with both Illinois and Pennsylvania in the mix. 

“We have continued to see different businesses, including some interest from data centers in the PECO territory,” said utility CEO David Velazquez. “We have the infrastructure to support that … on the generation side and also have the transmission infrastructure.” 

“In addition to data centers, we’re seeing electrification; we’re seeing development around the South Philadelphia area,” Exelon COO Michael Innocenzo added. “So, lots of opportunities for growth in all sorts of electrification.”

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OSW, Data Centers Loom Large in Dominion’s Outlook

Dominion Energy expects to start installing monopiles for the Coastal Virginia Offshore Wind (CVOW) project between May 6 and 8, CEO Robert Blue told analysts May 2 on the company’s first-quarter earnings call. 

Construction is moving forward despite a lawsuit seeking to stop the project, alleging its federal approvals violate the Administrative Procedures Act and the Endangered Species Act, Blue said. (See Opponents Sue to Halt Coastal Virginia Offshore Wind.) 

Proponents of the project have asked the U.S. District Court for D.C. to stop the project, but the suit is still pending, with Dominion set to file a response May 6 and its opponents their answer to that May 9.  

Blue said the complaint was without merit and that he expects the court to deny the plaintiffs’ request for a preliminary injunction. He said similar litigation against offshore wind has been rejected by an appeals court. 

“Let me just reiterate, the project is proceeding on time and on budget consistent with the timelines and estimates previously provided,” Blue said. 

CVOW got its eleventh and final required permit and Dominion has received 36 monopiles from its supplier, a fifth of the total. It expects more monopile deliveries in the coming weeks and will be installing them over two seasons — this year and next, Blue said. 

Offshore construction contractor Deme recently completed a project off Scotland that uses the same Siemens Gamesa wind turbine that CVOW will use, and the lessons learned there will benefit Dominion’s wind farm, Blue said. 

Dominion expects the levelized cost of energy (LCOE) for CVOW to be $73/MWh, which is down modestly from its last forecast due to higher renewable energy credit (REC) prices. That means the CVOW is expected to produce more benefits for customers, Blue said. 

“We remain well below the legislative prudency cap on this metric, and I would point out well below the PPA prices being considered in other parts of the country,” he added. 

Return to Capacity Auctions

Dominion has so far invested $3.5 billion in CVOW and remains on track to bring that up to $6 billion by the end of the year, with 93% of project costs fixed, Blue said. 

The other big issue in Dominion’s territory is data center growth in Loudoun County, Va., outside of D.C., and home to Data Center Alley, the largest group of data centers in the world. 

“In aggregate, we’ve connected 94 data centers with over 4 GW of capacity over the last approximately five years,” Blue said. “We expect to connect an additional 15 data centers in 2024. Northern Virginia leads the world in data center markets.” 

Both the number and the size of data centers seeking service in the area has grown in recent years. Dominion used to get requests to serve data centers requiring about 30 MW, but now individual buildings can use 60 to 90 MW, while the utility has gotten some requests for big campuses with multiple buildings drawing 300 MW to several gigawatts, Blue said. That growth in data center demand is reflected in PJM’s capacity market. 

“Last month, PJM released its capacity auction planning parameters,” Blue said. “The results aligned with our analysis of low growth and the need for requisite dispatchable supply resources included in our 2023 IRP. This independent modeling also validates the need to expediently progress the recurring local and PJM regional transmission planning and expansion process, and our decision to expedite numerous projects over the last two years.” 

Dominion has accelerated plans for new 500-kV transmission lines and other infrastructure in Northern Virginia and was awarded over 150 projects totaling $2.5 billion from PJM’s regional plan released in December, he added. (See PJM Board Approves $5 Billion Transmission Expansion.) 

The recent capacity market reforms and those latest assumptions mean Dominion will be participating in the main PJM Reliability Pricing Model auction once again, instead of using the Fixed Resource Requirement alternative as it had in recent years. It must decide which to pick later in May, with the auction set for July 17. 

“It makes sense for us to return to the capacity auction starting with the 2025/26 auction — [it] returns us [to] the way we did business for many years,” Blue said. “It doesn’t change guidance, doesn’t change the way we operate our system, or the way we think about the world.” 

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Ørsted Reports Steadier Course as US Market Stabilizes

The world’s leading offshore wind developer charted a path forward from the industry’s recent turmoil as it released its first-quarter financial results May 2. 

In a conference call with financial analysts, Ørsted CEO Mads Nipper said the company is confident the plan is coming together for the successful construction of Revolution Wind and Sunrise Wind off the Northeast U.S. coast. 

He outlined steps taken to prevent a repeat of the series of setbacks that cost Ørsted billions of Danish kroner in 2023 as it tried to navigate the U.S. offshore wind market’s growing pains. 

The company said its financials for the first three months of 2024 were in line with expectations, with offshore earnings 18% higher than in the same quarter in 2023. The company’s stock closed 2.7% higher May 2, a marked contrast to the plunges that followed some of the company’s 2023 announcements. 

Nipper and CFO Trond Westlie laid out some first-quarter highlights for Ørsted: 

    • The company secured a provisional contract with New York for Sunrise Wind to replace a previous deal that did not cover rising construction costs; this allowed the company to reverse some of the impairments it previously assigned to that project. 
    • Federal regulators green-lighted construction of the 924-MW Sunrise. (See BOEM Approves NY’s Sunrise Wind OSW Project.) 
    • The company is moving to take full ownership of Sunrise as 50-50 partner Eversource completes its exit from offshore development. (See Eversource Finds OSW Buyer, Takes $1.95B Hit for 2023.) 
    • Ørsted submitted a proposal for a 1.2-GW project it calls Starboard Wind to Connecticut and Rhode Island. 
    • It is moving to secure heavy structural steel for monopile foundations and additional installation vessel capacity — two critical potential roadblocks to project construction. 
    • Ørsted and Eversource completed construction of South Fork, the first utility-scale offshore wind farm in U.S. waters; final commissioning is expected in the second quarter. (See First Large US Offshore Wind Farm Complete.) 
    • Ørsted paid out 700 million kroner — about $100 million U.S. — for wind wake losses at Hornsea 1 attributed to Hornsea 2. Wind wake loss, which is output reduction in downwind turbines because of turbulence from upwind turbines, is expected to be an issue as more and larger turbines are installed. (See Researchers Modeling Jet Stream Interference with OSW.) 
    • March was the first month ever that the company burned no coal at its seven combined heat and power plants. 
    • Ørsted agreed to sell four U.S. onshore wind farms rated at 957 MW as part of its farm-down program, in which it sells operating assets to raise money for future projects. 

When Nipper and Westlie concluded their presentations, the Q&A portion conference call became a wide-ranging forum on prospects for Ørsted amid an industry reset. 

Some of the talking points: 

What happens if Ørsted needs more monopile capacity? 

“What we are very happy to see is that the actual production of the monopiles from our key supplier for three of our projects has stabilized so now the planning becomes safer,” Nipper said. 

If Ørsted won a contract for Starboard, would that not push the company above its targets for development in the United States? 

“No, this would be with all possible likelihood for a post-2030 [commercial operation date] and COD flexibility was one of the key criteria we assessed when deciding where and with what to bid,” Nipper said. 

Regarding Ørsted’s announcement May 1 that it had secured licenses to develop up to 4.8 GW of offshore wind in Australia: Isn’t Australia a rather immature market with no offshore wind supply chain? Didn’t Ørsted just go through this scenario in the United States? 

“So, this is not a market where you should be concerned that we will end up in the U.S. situation. Because we have learned — the entire industry have learned — that it is certainly a challenge to build a new industry entirely from scratch and I think both we and the entire industry are taking those learnings,” Nipper said. He added, however, that it is important to build longer-term opportunity, and Ørsted can do it at very limited cost with this move in Australia. “We will go there with very open eyes as to what are the risks that would come with an entirely new market.” 

New York just saw an entire wind solicitation collapse because the three contracts were relying on an 18-MW GE Vernova turbine design whose development was canceled. (See NY Offshore Wind Plans Implode Again.) What turbine are you planning for Sunrise, and is it on the market yet? 

“We can confirm that this is not on a future model that we are hoping will be there,” Nipper said, without providing details. (He had disclosed earlier in the call that 11-GW Siemens Gamesa turbines would be installed at Sunrise.) 

Ørsted’s problems in the United States probably can be traced to the defunding of the Bureau of Ocean Energy Management five years ago. What risk do you face if a future president attempts to intervene in the market again? 

“Yes, you’re right, that there are certainly risks that we are very explicitly handling. Most importantly [will be] to ensure that we have all permits in place [before the 2025 inauguration], which we feel comfortable we will,” Nipper said, adding that Ørsted put so much timeline flexibility in the Starboard bid for exactly that reason. He said, however, that bipartisan support for offshore wind has evolved over those five years. “Despite some of the rhetoric, this is being recognized that a very high joint priority in both blue and red states is job creation and we do see being recognized that offshore is creating jobs.” 

Do you think offshore wind development costs have peaked, or even reached a deflationary environment? 

“I don’t think it’s possible to say whether there’s a peak in pricing. But it is a fact that the supply chain inflation is a lot less steep than where we came from. But it is still too early to say whether that is flattening or even deflationary,” Nipper said. 

How is the farm-down program going? 

“We are continuing as we have planned, and what we actually see in the market is that even though the pricing of the assets has been higher or lower due to the fact of the interest rate … we see a slightly better sort of market and also interest in that regard,” Westlie said.  

Do you plan to keep a strong presence in the U.S. onshore wind market or rebalance to Europe? 

“Clearly the U.S. will remain our biggest onshore market. We do have a pipeline, and one where we also see several attractive opportunities and also are quite excited about some of the opportunities that are in combined generation and storage,” Nipper said. 

Any update on Ørsted’s plans to reuse equipment from the canceled Ocean Wind projects in New Jersey or the Skipjack project, which is in limbo in Maryland? (See Ørsted Cancels Ocean Wind, Suspends Skipjack and Ørsted Cancels Skipjack Wind Agreement with Maryland.) 

“Not a lot of update. We do continue to mature those opportunities,” Nipper said. 

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Senators Call for ‘Increased Accountability and Transparency’ at ISO-NE

In a wide-ranging letter dated April 30, four U.S. senators called for improved transparency and accountability from ISO-NE and asked the RTO to increase its facilitation of the clean energy transition.   

Sens. Ed Markey (D-Mass.), Sheldon Whitehouse (D-R.I.), Elizabeth Warren (D-Mass.) and Bernie Sanders (I-Vt.) applauded ISO-NE’s “ongoing progress on transparency, longer-term transmission planning and resource accreditation,” but said more changes are needed. 

“ISO-NE must address issues of governance with increased accountability and transparency, strategically build out transmission capacity and reshape the ISO-NE market structures that have a history of unfairly subsidizing existing fossil fuel generation,” the senators wrote, requesting a written response by May 10. 

The letter was led by Markey, a frequent critic of ISO-NE. In 2023, Markey introduced a bill to increase the transmission planning and transparency requirements for RTOs, which was endorsed by several environmental organizations. (See Dems Introduce Bill on Transmission Planning, RTO Transparency.) 

ISO-NE spokesperson Mary Cate Colapietro said the RTO is preparing a response to the letter and added that it remains focused on reliability and “managing wholesale electricity markets that will support the new technologies and industry innovations necessary to serve all New Englanders now and in the future.”  

Governance Recommendations

The senators urged ISO-NE to diversify its board of directors to better represent consumer, climate and environmental justice perspectives. They also called on ISO-NE to allow stakeholders to vote on individual candidates for the board, instead of just a single proposed slate of candidates.  

The board also should open its meetings to the public and make efforts to incorporate community feedback and questions into their proceedings, the senators added.  

The senators also criticized the voting structure within NEPOOL, noting that state consumer advocates “hold less than 2% of the voting power in NEPOOL.” 

While commending ISO-NE’s agreement to hire a policy adviser focused on community engagement and environmental justice, the senators asked ISO-NE to develop a larger environmental justice team “to uplift lived experiences, account for social costs and benefits, and align with larger environmental justice priorities.”  

The senators also asked ISO-NE to “engage more deeply with the ISO-NE Consumer Liaison Group (CLG) to ensure that public interest is a core tenet of all future decisions and policies.”  

Following the election of a group of climate activists to the CLG’s coordinating committee in December 2022, ISO-NE has seen strong participation — and faced increased criticism — at CLG meetings. (See Climate Activists Take Over Small Piece of ISO-NE.)

Interactions between ISO and NEPOOL officials and climate activists at the CLG at times have been testy. Activists have argued ISO-NE and NEPOOL are biased toward fossil fuel interests and aren’t doing enough to facilitate decarbonization, while ISO-NE has stressed that it must remain fuel-neutral and is constrained by federal and state policy.  

An April 1 letter to ISO-NE by two NEPOOL members criticized members of the CLG coordinating committee for advocating for climate action and urged ISO-NE to prohibit the committee from “lobbying from within.” 

The letter was written by Lisa Linowes, executive director of the Industrial Wind Action Group, an antirenewables advocacy organization, and William Short, a consultant representing multiple companies at NEPOOL.  

“If this level of advocacy persists, we would argue that the CLG be abolished,” Linowes and Short argued. 

The senators urged board members and ISO-NE officials to “continue to participate in CLG meetings in order to fully assess and understand the impacts of its decisions on the communities it serves and who pay for its operation.” 

Market and Planning Recommendations

The senators called on ISO-NE to redouble its intra- and interregional transmission planning efforts, while praising the proposed cost-allocation framework for long-term transmission projects approved by the NEPOOL Participants Committee in early April. (See NEPOOL PC Supports Additional Delay of FCA 19.) 

“In partnership with state governments, ISO-NE should embrace a much more ambitious paradigm for interregional grid coordination and planning with neighboring balancing authorities on both sides of the border,” the senators wrote. 

Regarding ISO-NE’s in-development resource capacity accreditation (RCA) updates, the senators wrote that ISO-NE should “expand the scope of RCA to better reflect gas plant performance, and ensure accreditation values adequately incentivize the resources states’ policies demand to participate in the capacity markets.”  

The RCA updates likely will significantly change the revenue resources can earn in the capacity market. ISO-NE’s initial analysis indicated the updates would hurt the value of gas, oil and battery resources, and benefit wind, energy efficiency and hydro resources. (See NEPOOL Markets Committee Briefs: Feb. 6, 2024.) 

Despite recent efforts to enable smaller resources to participate in ISO-NE’s wholesale markets, stakeholders have argued the markets remain prohibitive to aggregations of distributed resources. (See ISO-NE CLG Highlights Importance of Demand Response.) 

The senators expressed their hope the capacity market changes will prevent expensive out-of-market agreements to preserve grid reliability and stressed that any future out-of-market arrangements must be based on “clear, cohesive and transparent evidence.” 

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NC Residents Criticize Duke’s Pace of Coal Retirements, Reliance on Gas in Carbon Plan

North Carolina residents in an online hearing April 23 called upon the Utilities Commission to address Duke Energy’s preferred carbon plan, criticizing its slow pace of coal plant retirements and increase in gas plants compared to other options. 

The plan projects three “pathways” the utility could take to reduce its carbon emissions by 70% from 2005 levels by 2030, 2033 and 2038. All three pathways would eliminate Duke’s carbon emissions by 2050, according to the plan, but details concerning the utility’s resource mix beyond 2038 are not mentioned. The commission must approve any plan Duke puts forward before it is enacted. 

Pathway 3, with the most gradual pace of retirements and several large coal plant retirements delayed until 2036, is Duke’s preferred, least-risk option. The company would add 5,625 MW of solar by 2031, 2,700 MW of battery energy storage by 2031, 1,200 MW of onshore wind by 2033 and approximately 4,400 MW of new gas-fired generation by 2032. 

The speakers, all residents within Duke’s North Carolina footprint, took issue with the company “kicking the can,” as resident Allison Kubisko said, on the state’s 2030 goal of reducing emissions by 70% by delaying coal plant retirements. 

“I want to stress my concern about climate change and the need to reduce carbon emissions now. … Later is too late to reduce our emissions and to reduce our fossil fuel use,” Kubisko said. 

The law enacting the 2030 deadline, HB951, does include stipulations for when the commission can issue a delay, including to maintain existing grid reliability or to enable the construction of specific nuclear or wind generation. However, such delays cannot exceed two years, raising concerns about “pushback from the [North Carolina] legislature or even possible legal challenges” should the commission accept Duke’s plan unaltered, resident Matthew Mayers said.  

Putting off the state’s emissions goals could also exacerbate environmental and health issues, Durham resident Betty Matteson said. 

“Our children and grandchildren love to spend time” at Wrightsville Beach, she said. “Scientists tell us that the warming climate will cause rising sea levels and increasingly frequent and intense hurricanes … and I wonder when sea-level rise or a destructive hurricane will threaten our beloved Wrightsville.” 

Residents were also concerned about the buildout of gas-fired generation, particularly in neighboring South Carolina. Generation constructed there would not contribute to emissions reported in North Carolina, they said, even if the state’s residents used its power. Pathway 3 has over 7 GW of gas-fired power in place in 2038, compared to over 6 GW in Pathway 2 and just over 5.3 GW in Pathway 1. 

Matteson expressed specific concerns about residents’ cardiovascular health, which she said is known to be affected by air pollution from burning fossil fuels. She cited North Carolina State University research linking gas pipeline prevalence to nearby residents’ health and economic status as a reason to halt gas infrastructure buildout.  

“By reducing our dependence on fossil fuels, our children could enjoy a healthier future,” she said. “Why is this not the No. 1 priority of the 2024 carbon plan?” 

Cost Analysis

In addition to concerns surrounding emissions, residents opposed the carbon plan’s potential costs to Duke customers. 

Resident Judith Maddox and others said Duke prioritized its bottom line over actual costs in its favored plan. North Carolina regulations allow utilities to recoup gas infrastructure costs, “which makes it profitable for them to request such buildings,” she said. “Then they can turn around and charge customers for the gas costs that are required, whereas wind and solar do not have fuel costs.” 

In the plan Duke labeled as riskiest, Pathway 1, the company tacked on a 20% adder, or “cost risk premium,” to capital costs to account for the “extraordinarily aggressive” energy transition. This pathway would see 2.4 GW of offshore wind installed in the state by 2035, for example. 

This cost is “arbitrary,” resident Lisa Dietz said, given that Duke’s plan for gas and nuclear in the other two pathways is “overly optimistic … in terms of cost, timeline and future fuel availability.” 

In-person public hearings on Duke’s carbon plan also took place in Wilmington and Durham on April 29 and 30, respectively. 

Company spokesperson Bill Norton said the hearings were “about how [Duke] is going to supply the reliable, clean energy need to support North Carolina’s growing economy — while also getting out of coal and reinvesting in power plant communities to lower the cost of the energy transition for all customers.” 

Following testimony from public staff May 28 and the commission’s technical conference June 17, Duke will have the opportunity to file rebuttal testimony by July 1. The commission’s final evidentiary hearing on the carbon plan will occur July 22. 

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Stakeholders Deliver Negative Reactions to Proposed MISO Capacity Accreditation at FERC

Stakeholder voices criticizing the design of MISO’s proposed, probabilistic capacity accreditation outnumbered those expressing support before FERC.  

MISO filed with FERC for a new, direct loss-of-load accreditation style in late March. The RTO wants to move to a capacity accreditation for all resources that blends resources’ historical availability with projected performance during simulated loss-of-load events (ER24-1638). (See MISO: New Capacity Accreditation Filing Imminent.) Stakeholders’ reactions to the filing rolled in this week.  

MidAmerican Energy protested MISO’s filing, saying the marginal accreditation style would lower dispatchable resources’ values across its fleet with little explanation and result in undue discrimination to renewable energy. The company said examples MISO provided earlier to stakeholders to illustrate capacity values showed “accreditation values were well below the resource’s actual performance.” 

“Compounding this issue, MidAmerican has been unable to recreate … MISO’s results or get information from …MISO that explains why MISO’s results are vastly different from actual operations,” it wrote to FERC.  

Consumers Energy likewise said MISO’s accreditation proposal suffers from a lack of data transparency around class averages. It said it was impossible to understand why MISO set a pumped storage class average of 98% in the summer and fall seasons but just 50% in winter and 67% in spring for a consistently dispatchable resource.  

MISO’s accreditation would use a two-step process. First, MISO would calculate a probabilistic, resource-class average accreditation using its loss-of-load expectation analysis. MISO then plans to tailor resource class-level accreditations to individual generators based on their availability during both normal operating conditions and high-risk hours, including hours with low margins or emergency events in place. MISO plans to give greater weight to hours that contain emergency or near-emergency conditions in the ensuing accreditation.  

Most resources’ credits would shrink under the new accreditation. Resources would be divided by fuel type: gas, coal, combined-cycle hydro, nuclear, energy storage, pumped storage, run-of-river, biomass, wind and solar. 

A joint protest from Sierra Club, Natural Resources Defense Council, Sustainable FERC Project, Fresh Energy and Clean Wisconsin argued that because MISO’s loss-of-load expectation analysis features heavily in its accreditation and would have “outsized” impacts, MISO should have included its loss-of-load study methodology for scrutiny in its filing. 

A group of seven transmission-dependent Midwestern utilities criticized MISO’s accreditation design for relying on its self-described imperfect loss-of-load expectation analysis and inappropriately grouping dual-fuel combustion turbines into the same resource class as single-fuel counterparts. They called the design “not yet ready for prime time” and asked FERC to reject it.  

The MISO Cities and Communities Coalition — a collection of local governments within MISO focused on decarbonization including Minneapolis, New Orleans, St. Louis and Des Moines — said it worried MISO’s probabilistic accreditation would stymie clean energy targets. The coalition said MISO hasn’t provided enough detail around how it will treat energy storage in modeling and dispatch for accreditation purposes. It also said it worried the accreditation devalues solar generation’s contribution by not recognizing solar would subdue an afternoon peak and send it later into the evening, thus reducing reserve requirements on all resources.  

Entergy and Cleco also argued that elements are missing from MISO’s proposal, including how MISO would distribute planned outages across resource classes in probabilistic modeling, how MISO would factor resource deliverability into accreditation and how MISO would model deployment of energy storage resources. The two said FERC should order MISO to make another filing to fill in those blanks.  

Alliant Energy said while it “understands the need for changes to MISO’s markets in the face of the evolving resource mix,” it asked FERC to be open to delaying MISO’s rollout beyond the 2028/29 planning year.  

Clean energy proponents — Advanced Energy United, the American Clean Power Association, Clean Grid Alliance, Invenergy, NextEra Energy Resources, the Solar Energy Industries Association and the Southern Renewable Energy Association — jointly asked FERC to reject the filing. They argued MISO’s accreditation proposal would “unrealistically undervalue certain resources below their actual and likely contributions to system needs.” They also said MISO’s filing lacks detail and argued the set of resource classes aren’t nuanced enough and omit “technological and geographical distinctions” that lower capacity contributions. 

On the other hand, DTE Energy said MISO’s accreditation is a “resource-agnostic approach that appropriately shifts resource accreditation to focus on time periods of greatest reliability risk.” Constellation Energy also said MISO’s approach would help address operating challenges wrought by an evolving resource mix, extreme weather and load growth.  

The Michigan Public Service Commission said it supported MISO’s move to a probabilistic accreditation, calling it a “culmination of historical incremental changes, along with rapidly changing conditions in recent years such as continuing resource transitions, rise in extreme weather events, shifting load patterns and the reduction of reserve margins.” The commission said the accreditation is an honest attempt to “address the growing misalignment of the current system, which fails to properly represent risk, and the reliability of resources in the context of newly developing risks.”  

The Organization of MISO States itself was more cautious with its backing. It said while it “broadly” supported the accreditation, it emphasized MISO’s three-year transition period is essential, particularly in understanding how the direct loss-of-load approach would affect not only accreditation, but how MISO would divvy up reserve margin requirements among load-serving entities (LSEs).  

MISO is set to apply its probabilistic model not only to resources participating in its capacity auctions but extend it to its calculation of planning reserve margin requirement, which it divides into responsibilities among load-serving entities.  

However, MISO’s filing did not detail how it would use the probabilistic model to allocate its planning reserve margin requirement among LSEs, leaving that to a later, separate filing. Today, MISO metes out the requirement on a load-ratio share.  

“Given the significant changes the (direct loss-of-load) methodology could impose on the resource planning efforts by LSEs and their respective retail regulators, and given the need for further discussions around modeling improvements, MISO’s proposed three-year transition period is an essential component of MISO’s filing,” OMS wrote. It asked that MISO publish semi-annual status reports on how the probabilistic model would influence reserve requirements so LSEs can make better generation investment decisions.  

Arkansas Electric Cooperative Corp. also expressed concern the new accreditation would introduce “dramatic changes to the capacity allocation process and increased financial burden for a significant number of LSEs.”