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April 13, 2025

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ERCOT Board of Directors Briefs: April 7-8, 2025

RMR Contract for CPS Energy Unit Faces Increased Costs, Delays

ERCOT’s plans to continue running a 55-year-old San Antonio gas plant scheduled for retirement are being endangered by increased costs and timeline delays. 

CEO Pablo Vegas told the Board of Directors during its April 8 meeting that “pretty significant findings” during CPS Energy’s inspection of its Braunig Unit 3 found that the boiler superheater header must be replaced. What originally was thought to be a two- or three-month delay could be as long as 12 months, he said. 

The cost to replace the heater header has not yet been estimated, but Vegas said the contractor inspecting the unit — built during the late 1960s and with a summer maximum rating of 400 MW — has found $2.7 million of incremental costs to repair and replace core components “of significant vintage.” ERCOT and the market already are on the hook for $45.85 million under the terms of Braunig 3’s reliability must-run contract. The budgeted amount is a 33% increase since CPS’ first estimate in November. 

Vegas said staff are working to validate the cost estimate of the heater header — “a fairly costly [replacement item],” he said — and other components with the original manufacturers and other potential suppliers. 

“We have gotten signals that there may be some components that need to be replaced that have longer lead times to get those components in and get the unit up and running,” he said. “We’ll be looking at the impact of those delays to understand what that means in terms of the actual availability potential and then evaluate the cost benefit of continuing to work through this maintenance and repair cycle with Braunig Unit 3, versus looking at some other alternative. That data is very new.” 

The delays have placed added importance on the use of 15 mobile generators as an alternative to extending the life of V.H. Braunig Power Station’s other two aging gas units, slated for retirement this year. The grid operator determined the generators and their 450 MW combined capacity is less risky and more cost-effective than using the two small units from the “Swinging ‘60s” with a combined summer maximum rating of 392 MW. (See ERCOT Board OKs Mobile Generators in San Antonio.) 

Vegas said final negotiations are ongoing between LifeCycle Power, the mobile generators’ owner; CenterPoint Energy, which leases the generators; and CPS Energy, which plans to deploy them in the San Antonio region. 

“We are planning to do everything we can to incentivize bringing these units on as quickly as possible in the San Antonio area,” he said. “Given the fact that we are seeing significant cost and potential schedule delays on the Braunig unit, it increases the importance of having these resources available during the peak parts of this summer.” 

“We’re putting as much pressure on those parties to get those issues wrapped up, but I’m pretty optimistic that we should be able to get all this resolved,” General Counsel Chad Seely said. “Getting those assets onto the grid sometime this summer … they’re all kind of contingent on everything being folded up together.” 

LifeCycle’s generators were projected in February to cost $54 million, including fuel costs and incentives. They can reach full output in 10 minutes, faster start times than the three Braunig units.  

Seely said that as every day passes without an agreement with the parties, more risk is placed on their availability by August, “when we really need them.” 

Responding to questions from directors as to whether there is a drop-dead date before “punting” the generators, Vegas responded, “There isn’t a scenario where we’re going to punt this for this summer.” 

Kristi Hobbs, ERCOT’s vice president of system planning and weatherization, told the board staff has been work with CPS, AEP Texas and South Texas Electric Cooperative to accelerate portions of a $435 million reliability project south of San Antonio. The rebuild addresses a transmission constraint that has led to Braunig 3’s RMR contact and the mobile generator must-run alternative. 

The CPS board on March 31 agreed to a $150 million contract with Quanta Services to work on 58 miles of energized transmission lines. Quanta has agreed to complete the work by December 2026, shortening the original 2029 timeline. 

“We would be able to potentially exit both the Braunig 3 as well as the LifeCycle agreement as early as September of 2026,” Hobbs said. 

ERCOT’s RMR contract with Braunig is its first since 2016, when it entered into an agreement with NRG Texas Power over a previously mothballed gas unit near Houston. The RMR contract ended in 2017, thanks partly to transmission facilities that increased imports into the region. (See ERCOT Ending Greens Bayou RMR May 29.) 

CPS told ERCOT in 2024 that it planned to retire the Braunig units in March 2025. However, ERCOT said the plant’s retirement would lead to reliability issues in the San Antonio area until the transmission constraint is resolved. (See ERCOT Evaluating RMR, MRA Options for CPS Plant.)

Costs Increase for Permian EVH

Hobbs also told the board that staff has filed updated cost estimates for EHV transmission paths into the Permian Basin with the Public Utility Commission, which will determine whether to go with 345- or 765-kV lines. (See “EHV Lines Offer a Lifeline,” Texas Stakeholders Grappling with Tsunami of Large Loads.) 

The estimates provided by transmission providers have increased for both voltage options from the original May 2024 projections. The 345-kV option has increased 7.6% to $8.28 billion, while the 765-kV option has increased 11.6% to $10.11 billion. 

“We recognize it’s going to be an investment for the consumers to be able to get the transmission built that they need,” Hobbs told directors. “We’ve often said that we feel like our current transmission system has maximized its capability, meaning we have squeezed all we can out of the current transmission system.” 

ERCOT CEO Pablo Vegas | © RTO Insider

ERCOT said its analysis indicates that 765-kV circuits would provide “significant economic and reliability benefits” to the system because they are more efficient in moving power over long distances. Transmission providers and vendors said during a March 7 workshop that supply chain issues are not a concern. 

The PUC is scheduled to take up the issue during its April 24 open meeting.  

Operations Vice President Dan Woodfin also updated the board on a “pretty eventful month (March)” for renewable energy. Multiple wind, solar and total renewable records were set during the month: 

      • Wind generation: 28.5 GW, March 3.
      • Solar generation: 26.3 GW, March 20.
      • Solar penetration: 56.60%, March 20.
      • Renewable generation: 39.99 GW, March 18.

      • Renewable penetration: 76.11%, March 2.

Designing Residential DR Program

ERCOT is working with stakeholders to develop a residential demand response program to address short-time reliability problems, Keith Collins, vice president of commercial operations, told the board. 

“We do think that there’s an opportunity in terms of smart devices, thermostat, pool pumps, water heaters, things along that line, and to allow for a program that [focuses] on those types of resources,” he said.  

Collins said expanding the DR program is a top priority for ERCOT. As envisioned, it would provide an incentive payment to retail electric providers — and possibly public power entities in the competitive market — based on residential DR performance during highest net-load periods. 

“The intent of the program is something that’s quick to develop, simple in its administration, can be popular for folks to be a part of and ultimately is cost-effective in the end,” he said. “We do think we have some novel concepts that we’ll be able to accomplish.” 

ERCOT expects to complete the program’s design this year, develop it in 2026 and implement it in 2027, Collins said.

Possible Admin Fee Decrease in ’26

The board’s Finance and Audit Committee began its review of the ISO’s proposed 2026/27 budget, which could result in a 2-cent decrease in the system administration fee, said Flores, who presided over the committee meeting after Aguilar’s resignation.  

He said staff has proposed the fee be reduced from $0.63/MWh to $0.61/MWh, effective Jan. 1, 2026. The budget’s total authorized spend is $474 million in 2026 and $557 million in 2027. The increase is due to the start of ERCOT’s data center refresh project. 

The F&A will review the budget again during its June meeting. Flores said the committee has asked staff to bake in several uncertainties during the planning process, including trade tariffs and disruptions and a potential economic downturn’s effect on electric demand.

Aguilar Resigns, R&M Dissolved

Board Chair Bill Flores opened the meeting by announcing Carlos Aguilar resigned as an independent director. Aguilar was one of the first two directors to sit on ERCOT’s revamped board following Winter Storm Uri in 2021. His second term began in October 2024. 

“His expertise and guidance have been instrumental in this board’s decision-making,” Flores said. 

The ERCOT Board Selection Committee, composed of three members selected by Texas’ governor, lieutenant governor and speaker of the House of Representatives, will begin the selection process in coming weeks, Flores said. Under state law, all board members must be Texas residents. 

The board voted to dissolve its Reliability and Markets Committee and move its discussion to the full board. The R&M committee was created in 2022 and was responsible for core ISO functions and several technology-related functions that later were shifted to the Technology and Security Committee. 

Flores moved the R&M’s jurisdiction to allow all board members more direct participation in policy matters associated with the core functions of operations, planning and markets. He said future board meetings likely will be held over two days to manage business more efficiently.

ERCOT to Sublicense Patents

Seely told the board the grid operator will enter into a patent-license agreement with Lancium, a Texas-based energy technology firm.  

Seely said the company’s patents may be a barrier to entry for increased market participation by controllable-load resources (CLRs) if that risks intellectual-property infringement disputes. Lancium is registered with ERCOT as a qualified-scheduling entity (QSE), load-serving entity and resource entity. It owns a portfolio that includes a patent focusing on determining performance strategies for loads using power option data based on a power option agreement. 

“This is a longstanding issue that’s been kind of playing around the surface in the stakeholder process for a couple of years,” Seely said. There have been “arguments around the patents” with stakeholders. “ERCOT has been engaged with Lancium for quite some time trying to understand the impact of what those patents could mean to our CLR program.” 

Under the agreement, Lancium will license its relevant patents to ERCOT at no cost. The grid operator then will sublicense the patents to CLRs and any other applicable market participants or entities. 

“This is a good outcome in which we can resolve this issue for the ERCOT region,” Seely said.

Board Approves RTC Protocols

The board approved a key protocol change (NPRR1269) related to ERCOT’s real-time co-optimization project, thought to be the foundation for future market improvements and scheduled to be deployed in December. (See “Stakeholders Approve Protocol Changes for Real-time Co-optimization,” ERCOT Technical Advisory Committee Briefs: March 26, 2025.) 

NPRR1269 determines and codifies policy changes that were deferred from the original RTC-related protocols developed after the project’s inception in 2019: ramping scaling factor values; ancillary service (AS) proxy offer floor parameters; and ancillary service demand curves’ (ASDC) use in reliability unit commitment (RUC) studies. 

Two other RTC protocol changes, NPRR1268 and NPRR1270, were placed on the board’s consent agenda. 

Benjamin Barkley, the Office of Public Utility Counsel’s CEO, voted against the motion, saying setting the ASDC demand floor at $15 without seeing how it would perform with RTC is “premature.” 

“Set [the floor] at $0 just to see how the market would respond in that circumstance,” he said. 

Buckley again cast the lone dissenting vote against NPRR1190, which allows recovery of a “demonstrable financial loss” arising from a manual high dispatch limit override reducing real power output, when the output is intended to meet QSEs’ load obligations. The Technical Advisory Committee lowered the $10 million threshold that would trigger a review to $3.5 million. (See “Amended NPRR Passes,” ERCOT TAC Opens Discussion on Proposed RTC Changes.) 

The directors also approved a correction of real-time prices for some operating days between Aug. 12 and Sept. 11 in 2024. A software update to ERCOT’s energy management system resulted in stale telemetered MW values, leaving the ISO short $3.3 million in statement charges. 

The board’s consent agenda included six other NPRRs, two changes to the Planning Guide (PGRRs), single changes to the Nodal Operating and Settlement Metering Operating (NOGRR, SMOGRR), a system change request (SCR) and a modification to the Verifiable Cost Manual (VCMRR): 

      • NPRR1234, PGRR115: Establishes interconnection and modeling requirements for large loads, defined as one or more facilities at a single site with an aggregate peak power demand of 75 MW or more.
      • NPRR1241: Clarifies the hourly standby fee clawbacks for firm fuel supply service during a winter weather watch by using a sliding scale.
      • NPRR1256: Changes language in adjustment period and real-time operations protocols related to must-run alternatives (MRAs), primarily in grey-boxed language from NPRR885 (Must-Run Alternative Details and Revisions Resulting from PUCT Project No. 46369, Rulemaking Relating to Reliability Must-Run Service) to align the terminology for energy storage resources (ESRs) in the single-model era. It also specifies how qualified scheduling entities representing ESR MRAs would be settled for providing MRA service.
      • NPRR1268: Defines the methodology for disaggregating the operating reserve demand curve into blended ancillary service demand curves.
      • NPRR1270: Updates requirements for load resources that are changing under RTC and were not updated in earlier revisions; removes language associated with group assignments in the day-ahead market; and eliminates the automatic qualification of all resources to provide on-line non-spinning reserve and SCED-dispatchable ERCOT contingency reserve service, among other changes. Resources will be required to undergo a qualification test to provide each of these services.
      • NPRR1273: Modifies ESRs’ capacity to the amount sustained for 45 minutes included in the physical responsive capability’s calculation.
      • NOGRR274: Conforms the guide to NPRR1217’s (Remove Verbal Dispatch Instruction Requirement for Deployment and Recall of Load Resources and Emergency Response Service Resources) protocol changes.
      • PGRR119: Codifies that a reliability margin will be used when limits associated with a stability constraint are modeled in the Regional Transmission Plan’s reliability and economic base cases.
      • SCR829: Adds an application programming interface to upload and download unit testing data from the net dependable capability and reactive capability application.
      • SMOGRR028: Gives guidance for allowing loss compensation for current limiting reactors.
      • VCMRR042: Adds seasonal sulfur dioxide and nitrogen oxide prices obtained from indices to calculate emission costs from May through September; annual prices would continue to be used from October through April.
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NY Energy Summit: Slow and Cautious Progress Offshore

ALBANY, N.Y. — The state with some of the most ambitious goals for offshore wind energy continues to pursue them as federal policy changes force a slowdown.

At the April 7-9 New York Energy Summit, updates on energy development efforts off the New York coastline did not gloss over President Donald Trump’s war on wind turbines but did not focus on it, either.

Some milestones have been achieved, panelists said, and just as important, no one has given up on reaching the next milestones.

Gregory Lampman, director of offshore wind at the New York State Energy Research and Development Authority, called the present situation a pause: The offshore wind industry and the various entities working with it are waiting to see how federal regulators interpret and execute President Trump’s directives targeting offshore wind.

NYSERDA wants developers to continue to invest in their lease areas during this period, Lampman said. It also would like shorter timelines between key milestones in the development process, which would lessen the risks and costs that grow with delay.

“Continue to invest in those areas, continue to refine and get more prepared, so that when we start moving through this regulatory process again, we can jump on it, make some progress, and then move much more projects into construction, very quickly,” he said.

New York Offshore Wind Alliance Director Alicia Gené Artessa said the nine offshore wind developers she represents remain interested in the New York market. “They want to build here because we have New York City and Long Island, which need power, and those are a lot of needy customers to say the least.”

John Dempsey, CEO of Bluepoint Wind | © RTO Insider

As an early-stage project, Bluepoint Wind is taking a longer view for its lease area in the New York Bight, CEO John Dempsey said.

“We still would not see turbines spinning until the early 2030s regardless of who was president,” he said. “So it’s more for us about using the time to get the ecosystem in a good spot for the future.”

The lack of that ecosystem — a supply chain, institutional knowledge, manufacturing capacity, port infrastructure — was one of the challenges limiting attempts to quickly build a large U.S. offshore wind sector a few years ago.

Offshore wind produces electricity on a larger scale than any other renewable, Dempsey said, and its problems have been larger as well. But the underlying basis for building offshore wind remains strong, he added — demand in the wholesale electricity markets will persist.

“Offshore wind is one of a handful of generation assets that deliver scale once we’re going,” he said, “so to me, it’s just about using the time we have here to get everything right, and particularly around transmission and offtake.”

Alicia Gené Artessa, New York Offshore Wind Alliance | © RTO Insider 

New York is giving more attention to offshore power transmission as it plans offshore power generation.

The first New York projects — South Fork, Sunrise Wind, Empire Wind 1 — rely on a radial model in which each wind farm has its own export cable and shoreline landing point. In its sixth solicitation, NYSERDA plans to effectively separate generation from transmission with a meshed transmission model that serves multiple wind farms.

Neither model is without challenges, and the overall cost and value of a meshed model would depend on the offshore wind generation attached to it. But Lampman said a meshed system such as the ones proposed into the NYISO’s public policy transmission needs solicitation could be “a great solution for growing the industry.”

He added: “It’s a bit of a challenge, though, because we’ve solved one problem and we sort of moved to another problem, which is, what are the commercial terms between the transmission developers and the offshore wind generators? And what’s the technical terms that get used? Because one group is building the transmission, the other one’s building the generation. How do you bring these things together?”

Gregory Lampman, New York State Energy Research and Development Authority | © RTO Insider

Bluepoint is farther from land than any other lease area in the New York Bight, and it could send power to New York or New Jersey. So it has a close interest in these potential transmission solutions.

Dempsey said New Jersey got an early start on offshore transmission development solicitations but had to pull back on the process, which affected Bluepoint’s own planning.

“So my hope is that New York continues with its plans around the PPTN, I think it’s a tremendous opportunity,” he said. “It obviously has some wrinkles to it that we need to iron out, but I think most of those are commercial in nature that we can figure out.”

The elephant in the room through all the conversations at the summit was the Trump administration and its ability to slow down renewable energy projects or boost their construction costs to untenable levels.

After the summit, a NYSERDA spokesperson told NetZero Insider the state still is waiting to see the practical impact of Trump’s Day 1 directives targeting offshore wind. The planning can continue amid this uncertainty because construction would be years away under any scenario.

“NYSERDA is carefully reviewing federal actions that impact our work.  It is too soon to determine what impact, if any, federal actions might have on New York advancing the state’s energy policies. In the meantime, we will continue to work with colleagues across state government to realize the benefits promised by our state energy policy.”

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Western Commissioners Ramp up Wildfire Efforts

LA JOLLA, Calif. — Western lawmakers have advanced efforts to provide the power industry with guidance amid increased wildfire risk, regulators discussed during the joint spring conference of the Committee on Regional Electric Power Cooperation and Western Interconnection Regional Advisory Body (CREPC-WIRAB).

After California passed Assembly Bill 1054 in 2019, the Golden State has launched several initiatives aimed at ensuring the law is integrated with how utilities “build, operate and maintain California’s electric system,” Caroline Thomas Jacobs, director of the Office of Energy Infrastructure Safety at the California Natural Resources Agency, said during a panel discussion on April 2.

AB 1054 established a wildfire fund that paying utilities can tap into to pay claims for damages resulting from a wildfire caused by utility equipment. Money in the fund comes equally from utility ratepayers and shareholders. (See California Wildfire Fund Could be Model for US, Panelists Say.)

The law also established a fire certification element. Safety certification requirements in California include having a wildfire mitigation plan, safety culture assessments and evidence of making progress on previous plans. In addition, executive compensation must be based at least 50% on safety metrics.

Thomas Jacobs said utilities have made significant progress, but “clearly, the risk has not been eliminated.”

“There’s 150 years of infrastructure out there that is built to allow sparks,” Thomas Jacobs said. “So, in today’s given environment, we’re not going to eliminate that risk overnight, but we are trying to layer that now into what the broader state effort is.”

Recent efforts to integrate utility efforts with the broader state system under AB 1054 include developing partnerships “so that we can start leveraging the massive amounts of investments that the utilities are investing on wildfire and making sure that’s paired with … the broader state system around wildfire resilience,” Thomas Jacobs said.

Also, the state’s Wildfire Mitigation Advisory Committee is coordinating initiatives with the Department of Insurance, communities and utilities to integrate wildfire mitigation work “into that broader state effort, Thomas Jacobs added.

‘Collective Responsibility’

Wyoming has similarly stepped up its wildfire prevention work. The state’s Legislature passed House Bill 192 in March following wildfires that burned thousands of acres in 2024.

The fires gave stakeholders a sense of urgency, said Mary Throne, a member of the Wyoming Public Service Commission and chair of WIRAB.

Wyoming’s wildfire law, which goes into effect on July 1, does not create a wildfire fund, but it requires all utilities to file wildfire plans with the state’s Public Service Commission, Throne said.

“The exchange for a wildfire plan that we approve, there’s limited liability protection,” Throne said. “It creates a presumption, a standard, a duty of care that applies as long as the company is in compliance with its wildfire plan and not engaged in gross negligence or malice.”

Throne noted that wildfire mitigation is a “collective responsibility,” adding that the utilities are not primarily responsible for the heightened fire risk.

Utilities “do have a duty of safe, adequate and reliable service for their infrastructure,” Throne said. “But again, we cannot put what is really sort of a broader societal burden on an entity and entities that keep the lights on. There’s got to be some collective skin in the game.”

Wildfires also pose economic risks, and the West has already seen examples of utilities going bankrupt after being found liable, said Spencer Gray, executive director at the Northwest & Intermountain Power Producers Coalition (NIPPC).

NIPPC represents power producers and marketers. The organization’s members “need entities on the other side of the contract who are going to attract capital, who are liable for the course of the contract, who don’t face unexpected bankruptcy or a suspension of their ability to pay,” Gray said.

“We’re in a situation now, in many states, where the risk is not knowable,” Gray said. “You can’t mitigate it sufficiently to go back to your shareholders or to the debt markets to address it, and so that that really is an untenable situation,” Gray added.

Efforts in Washington and Oregon are underway to address risk sharing, including enhanced wildfire planning requirements and the establishment of a fund for the benefit of wildfire victims, Gray said.

NIPPC has been supportive of these efforts and “we will continue to be supportive of creating a risk environment that’s more knowable — not riskless — for our counterparties,” Gray said.

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NYISO’s Firm Fuel Proposal Criticized by Market Monitor

NYISO’s market monitor claims the ISO’s firm fuel capacity accreditation proposal would incentivize generators to rely on inferior types of firm fuel service that could undermine the winter reliability benefits of firming up. 

“The current tariff is enforced through documentation, the need to obtain agreements that commit to firm fuel obligations,” said Pallas LeeVanSchaick, vice president of Potomac Economics. “The NYISO proposal fundamentally changes the obligation … by switching to something with a performance-based rule.” 

The NYISO proposal asks that generators elect as firm or non-firm roughly 16 months in advance of the capability period they are electing for. The proposal requires that generators electing firm notify the ISO they have secured firm contracts by Dec. 1 of the capability year.  

Generators that elect firm need to have fuel supply, transportation and replenishment strategies in place by the December deadline to ensure they can operate 56 hours over a consecutive seven-day period during the winter. Failure to perform during the capability period could result in sanctions. 

LeeVanSchaick said in a presentation April 9 to the Installed Capacity Working Group (ICAP WG) that NYISO’s current proposal creates an incentive for generators to rely on “inferior types of firm fuel service” to qualify as firm. That’s because of the way it interacts with the natural gas import infrastructure.  

During most periods, “firm” gas used by generators is made available on the system through capacity release, LeeVanSchaick said. Capacity release is the reselling of firm fuel rights to another entity. These can be pre-arranged for set terms of time.  

“Most of the gas that’s available during winter is mostly a function of capacity release,” LeeVanSchaick said. “It’s not something that’s going to be available under all circumstances.” 

During the worst winter periods, more generators are called on, reducing available fuel. If more generation is called on than there is natural gas available, then they must rely on fuel injections at the LNG ports in New Brunswick and the Boston area. These periods are infrequent. Most generators, LeeVanSchaick said, don’t bother coming up with firm fuel transportation contracts. 

“A performance-based penalty doesn’t provide a very strong incentive to do this,” LeeVanSchaick said. “You’re sort of relying on generators to ignore their incentives.” 

LeeVanSchaick said the purpose of firm fuel capacity accreditation is to try to incentivize generators to have capacity for infrequent conditions. He said it requires either verification of firm fuel and transport contracts on the front end, which the NYISO proposal does not do, or extreme penalties to make a violation too risky.   

He proposed levying an additional firm fuel penalty on any generator that notifies the ISO of failure to contract by Dec. 1. For generators that are discovered to have not informed the ISO of a failure to get firm fuel contacts in place, he recommends a financial sanction and FERC referral. He also recommended moving the deadline up to March before the capability period.  

Representatives of the generator sector took issue with this analysis, saying there were penalties beyond the firm fuel sanction that they would be exposed to if they misrepresented how firm their fuel was. Specifically, misrepresenting how firm a contract was already could get a generator in trouble with FERC for a tariff violation.  

“I think the concern you raised is that this (getting firm fuel) is not a black-and-white behavior and therefore the ISO should allocate penalties,” said Mark Younger of Hudson Energy Economics. “I think if we’ve got issues that need to be evaluated where it’s not black and white, that FERC is the appropriate place to do that.” 

Younger said he was more comfortable with the clarity of the ISO proposal and there was nothing in it to prohibit the ISO from asking generators what they did to secure a firm resource.  

Doreen Saia, chair of the energy law practice at Greenberg Traurig LLP, said she wasn’t comfortable with a system that forced generators to declare they could lock down fuel supplies 15 months in advance, combined with a penalty if they couldn’t secure a contract because of market reasons.  

“It’s like having a cop on a road seeing a car go really fast and not know if it went 70 or 90 and therefore not know what kind of ticket it should get,” Saia said. “I think that’s a FERC question and FERC should decide whether any additional penalty should be required or not.” 

NYISO staff attending the working group disappeared during the lunch break to confer in private on the MMU proposal and the discussion it generated. They came back with an ellipsis.  

“We’d like to get any additional feedback or thoughts on the proposal that was put forward today,” said Shaun Johnson, vice president of market structures for NYISO. “We’ll take that feedback, process it and consider our next steps going forward.”  

Zack Smith, senior manager capacity and new resource integration market solutions for NYISO, said they would move “rapidly” with their considerations.  

Julia Popova, chair of the ICAP WG, asked about the timing of NYISO returning with an answer. The ISO is running out of time to file with FERC and avoid jostling the current Aug. 1 deadline.  

Smith said the ISO would return “soon” but didn’t provide a clearer timeline.  

“The message is clear. Stay tuned,” Popova said.  

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NY Energy Summit: Making the RAPID Act Live up to its Name

ALBANY, N.Y. — Speeding up the construction of new transmission and other energy infrastructure is a recurring topic of conversation each year at the New York Energy Summit.

The 2025 edition of the Infocast event included standard complaints and constructive criticism, but there also seemed to be more progress to report than in some years.

The April 7-9 Energy Summit fell shortly before the one-year anniversary of the Renewable Action Through Project Interconnection and Deployment Act.

The RAPID Act expanded the powers and responsibility of the Office of Renewable Energy Siting, in hopes ORES could create for major transmission proposals some of the same streamlining it has done for proposed large-scale renewables: a standardized and expedited permitting process that can override local authority if needed.

Recently appointed ORES Executive Director Zeryai Hagos brought the audience up to speed on the work of what officially now is the Office of Renewable Energy Siting and Electric Transmission but still is known as ORES.

“We’ve got a much larger volume of transmission projects that we already know exist and are coming, and we have many, many more that are going to get approved by the [Public Service] Commission, I think, in the coming years, as the [Coordinated Grid Planning Process] begins to develop its first real big slate of projects at the end of next year,” he said.

“And so primarily the purpose of the RAPID Act was to ensure that we could keep moving at the pace necessary to achieve the climate goals and not let transmission be a barrier.”

Hagos recalled coming to New York in 2019 and discovering what everyone else discovers: It was a slow and expensive place to build generation and transmission.

U.S. Rep. Daniel Goldman | © RTO Insider

Long-running efforts to address this have been complicated by events at the local and global level. Hagos recalled several such events during his tenure in New York:

Later in 2019, the state passed its landmark climate law, with statutory requirements that will radically increase the amount of electricity used in New York and radically decrease the amount of greenhouse gases emitted. (And radically increase the amount of generation and transmission capacity needed.)

In 2020, the COVID pandemic altered energy use patterns as people began to stay at home.

In 2022 and 2023, global supply chain and cost factors eviscerated New York’s portfolio of contracted clean-energy projects, likely making the first target of the climate law — 70% renewables by 2030 — unreachable.

Marguerite Wells, Alliance for Clean Energy New York | © RTO Insider 

Now in 2025, Hagos said, federal policy changes could actively thwart New York’s energy agenda, or make it more expensive to achieve, or both.

Interconnection queues are crowded and permitting reviews can be slow anywhere in the nation, not just in New York.

U.S. Rep. Daniel Goldman (D) focused on federal sluggishness in his remarks. “We really need to continue to streamline the process of getting clean energy up and running and on the grid. We need permitting reform,” he said, calling out specifically the irony of environmentally beneficial renewables being subject to the lengthy and rigorous reviews originally designed for environmentally unfriendly fossil fuel projects.

Max Luke, National Grid’s director of transmission and wholesale market policy, said the utility is optimistic about changes wrought by the RAPID Act as well as by FERC orders 1920 and 2023, and will work with NYISO and other stakeholders to continue refining the process.

The draft regulations promulgated through the RAPID Act are not complete — public comments are being accepted through April 18 — so their exact impact remains to be seen, Luke added.

Joel Thomas, AES Corporation | © RTO Insider 

“But National Grid is hopeful that that they will expedite transmission development considerably,” he said. “We’re faced with needing to build a lot more transmission in the state for a whole bunch of reasons, but a lot of that is driven by the state’s public policy objectives.”

ORES is not a magic bullet. It was intended to streamline the permitting process and limit the ability of local governments to stand in the way of policy goals, but it is not “drill, baby, drill,” a rubber stamp or a carte blanche. The application process is rigorous and complex, the pre-application process can take longer than the application process, and local opinion still matters.

One after another, developers, advocates and officials speaking at the summit warned against scrimping on community outreach or ignoring public opinion when pursuing energy projects.

Boralex public affairs manager Zack Hutchins said public outreach is even more important in the ORES era.

“The ORES structure has been extremely helpful as far as providing certainty and helping with timelines and all of that,” he said. “One of the unfortunate side effects of it has been that it’s created this tension between developers and local officials who feel that they don’t have a say.”

Max Luke, National Grid | © RTO Insider 

Boralex gets feet on the ground early and often when it is advancing a project, Hutchins said.

“And if we can prove that we provide value and that we can answer questions that [local officials] receive from angry citizens, then that gives us a leg up when it comes time to actually move into the development phase, the construction phase and then the operation phase of these various projects.”

Joel Thomas, who leads East Coast development for the AES Corporation, said a developer that waits until the permitting process to start pitching the project to the community has waited too long and can find themselves being reactive to people who already have made up their minds.

Alliance for Clean Energy New York Executive Director Marguerite Wells also emphasized proactive outreach. “You should be having dozens and dozens of community meetings before any public decisions get made,” she said.

Wells warned that the various streamlining efforts that ORES, NYISO and other New York entities are making are not simple changes:

Zack Hutchins, Boralex | © RTO Insider

“The promise and the challenge of the revised approach to managing the queue is that it’s going to deliver us projects out the other side that have been fully vetted in a much shorter period of time, but it is more expensive, and it requires a higher level of rigor going in and a higher level of financial commitment on the part of the developers throughout the process.”

As the one-year anniversary of the RAPID Act nears and the comment period on its draft regulations ends, ORES is trying to balance the many demands and expectations placed on it.

New York does not speak with one voice: It is a deep blue state by population but a heavily red state by geography. The red areas often are prime targets for energy development; some of them resent that fact and resent that ORES can override their objections.

More than 200 comments have been submitted about the RAPID Act draft regulations (24-M-0433), ranging from it being another dictatorial power grab to ORES not going far enough to shorten the permitting and pre-permitting processes.

“We recently extended the comment period because many stakeholders just thought that this was such a substantial change, and there was so much happening in the regulations,” Hagos said.

“We understand that there is a tradeoff between having really, really strong environmental protections and making sure we do it right, and also time — time and feasibility.”

And that provides a hint about a likely theme of conversation at the 2026 New York Energy Summit: How can we tweak New York’s permitting just a little further, and how can we assuage local discontent just a little more effectively?

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MISO: DR to Face More Stringent Testing by 2026 Capacity Auction

CARMEL, Ind. — MISO said its next capacity auction in spring 2026 will feature more rigorous testing for its demand response that registers to provide capacity. 

The grid operator said it will discontinue its practice of allowing its demand resources to provide hypothetical, mock tests as a performance indicator, except where state regulations might allow, for the 2026/27 Planning Resource Auction. 

The end of mock testing follows MISO enforcing stricter registration requirements ahead of the 2025/26 capacity auction offer window, which ran from March 26-31. (See Following DR Exploitation, MISO Announces Stiffer Requirements Before Capacity Auction.) Taken together, the more unyielding rules are a response to five recent instances of disciplinary action from FERC regarding companies deceitfully offering demand response in MISO’s capacity auctions. (See Voltus Agrees to $18M Fine to Settle DR Tariff Violations in MISO.)  

“There are concerns about the mock test, how it’s being used and the information around it,” MISO Market Design Economist Joshua Schabla said during an April 9 Resource Adequacy Subcommittee. “Frankly, it’s something we’re uncomfortable with.”  

Schabla said at times, mocks tests are “little more than a function in an Excel file.”  

MISO said all demand resources that plan to provide capacity beginning in June 2026 should be prepared to prove their capabilities via actual demand reductions to at least 50% of their stated seasonal values or down to a firm service level, if they specified one. Tests that show less than a 100% result need to be backed up with documentation explaining why a full reduction wasn’t possible.  

MISO said it wasn’t foreclosing the possibility that mock tests won’t ever be allowed among its demand response fleet in the future. So far, the testing requirement would apply only to the 2026/27 capacity auction.   

Schabla said MISO plans to require a real test of its load modifying resources (LMRs) once per year. The tests can be completed on the resource owner’s time and would count as one deployment. MISO’s LMRs currently are bound to deploy if necessary five times apiece in the summer and winter and three times apiece in spring and fall. 

Erik Hanser, of the Michigan Public Service Commission, said the new testing requirements won’t give resource owners much time because real power tests for the 2026/27 planning year begin in summertime up until LMR registration for the 2026/27 Planning Resource Auction begins Dec. 15.  

Schabla said MISO has not called LMRs since December 2022. The three-year downtime provides further justification that it’s time for LMRs to make a demonstration of their abilities, he said.  

“We need to see something positive, that this demand resource is real and can perform to requirements. … We need to see that it can do what we’re paying it to do,” Schabla said.  

MISO Independent Market Monitor David Patton said terminating the mock test practice is critical because the IMM has noticed mock test results submitted from LMRs with reduction levels that are “difficult to believe.” He said in some cases, LMRs appeared to fail a real power test and then decided to conduct a mock test instead. Patton said at this point, MISO likely is hosting and paying several megawatts of LMRs that either aren’t real or can’t achieve what they say they can.  

Patton said it’s “entirely fair” for MISO to provide notice now that it will enact stricter testing requirements, even if it doesn’t yet have FERC approval to end mock testing. He said LMRs should use the time to prepare for actual testing.  

Patton said MISO’s proposed 50% benchmark testing is “far too lax.” MISO pays LMRs too much to accept a 50% performance, Patton argued.  

“We’re going to continue to talk to MISO and stakeholders about that dimension of this proposal,” he said. 

MISO to Allow LMR Capacity Substitutions

MISO also said it will permit load modifying and demand response resources to replace their auction-cleared capacity with other, uncleared capacity in the event they’re unable to deliver promised load reductions. The change would also take effect in the 2026/27 planning year auction.  

MISO allows its more traditional resource types to replace zonal resource credits, but that allowance doesn’t extend to demand response resources and LMRs. In MISO, resources’ accredited capacity values are converted to zonal resource credits that are used in auction trading.  

MISO said it will allow LMRs to make similar, limited replacements if: the end-use customers it contracted for reductions must terminate contracts; regulations prevent the LMR from performing; or a change in ownership occurs in an end-use facility that the resource was banking on to shrink load. For behind-the-meter generation registered as LMRs, MISO said a planned outage longer than 31 days or a catastrophic outage would present the opportunity for replacements. 

MISO said in all cases, it may require documentation or evidence.  

Schabla said resources “must have a good reason to replace” and must be prepared to explain their situations to MISO and the IMM.  

MISO staff said they intentionally drafted narrow criteria for replacement conditions so auction commitments remain binding, and market participants don’t have a route to avoid obligations.  

Some stakeholders have said MISO’s replacement proposal is encouraging and will be helpful if facilities close and zonal resource credits need to be replaced. 

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IMM Praises MISO for Fewer Out-of-market Actions

CARMEL, Ind. — After years of its Independent Market Monitor critiquing MISO for making too many out-of-market actions to tame congestion, the IMM congratulated the RTO for dramatically reducing such actions over this winter’s sustained cold.

Speaking at an April 10 Market Subcommittee, IMM Carrie Milton said MISO operators’ manual actions for congestion management fell dramatically over the winter. She said despite record peak loads over the winter, MISO trusted its markets more and paid minimal uplift payments. (See MISO: Better Preparations Clinched Winter Storm Operations.)

The IMM has long advocated for the MISO control room to allow market-based interventions rather than operators making what it calls inefficient, out-of-market actions to manually redispatch or cap generation output.

By the IMM’s count, MISO operators ordered just 42 manual redispatches and generation caps over winter 2025, compared to 769 in winter 2024 and 1,236 in winter 2023 that the IMM previously cataloged.

“It almost looks like we’re missing data,” Milton said of the IMM’s striking graph comparing the instances of actions in winter 2023, 2024 and 2025. Milton called it a “very impressive result.”

Milton said MISO has worked to make better data available and has congestion management guidelines among control room operators.

Stakeholders asked if the IMM believed that the minimal out-of-market actions could be an enduring trend.

An illustration of the contingency reserve shortage on Feb. 19 | Potomac Economics

Milton said she thought MISO can reduce its extraneous actions in the long run, even if actions outside of the market tick up during spring. She said maintenance outage season combined with volatile spring weather and high wind likely will lend itself to more out-of-market interventions March through May.

“We understand if we don’t see the same result in the spring quarter,” Milton said.

Finally, Milton advised the MISO operations team to put more trust into its look-ahead commitment tool to call up units. If control room operators had followed the tool’s recommendation to procure and committed an additional 905 MW around 7 p.m. ET on Feb. 19, they could have avoided a contingency reserve shortage that day, Milton said. MISO committed only 450 MW, she said.

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FERC Issues Order 1920-B Upholding States’ Role in Cost Allocation

FERC issued Order 1920-B on April 11, denying rehearing requests on its previous iteration that mostly sought to overturn requirements that transmission planners file cost allocation methods agreed on by state regulators and that they are consulted on future reforms. 

Order 1920 gave states in a planning region six months to work on a cost allocation methodology, but it declined to require that they be filed by the ISO/RTO or other planning entity. That changed with Order 1920-A, which did require any agreed-upon cost allocation methods to be filed. 

Edison Electric Institute, WIRES, and some regional transmission owner groups argued in separate rehearing requests that forcing transmission owners to file state cost allocation methods, even if they disagree with them, intrudes on their filing rights under the Federal Power Act’s Section 205. That part of the law gives public utilities unilateral and exclusive filing rights to propose rates, terms and conditions of service that essentially places FERC in a reactive role. 

But FPA Section 205 is complemented by Section 206, which provides FERC with the authority to modify any existing rates after a finding that they are unjust, unreasonable or unduly discriminatory. 

A group of MISO transmission owners argued that the requirement to file state agreements disrupts the balance set by those two sections of the law — “allowing FPA Section 206 to usurp FPA Section 205,” the order said. 

“The compliance filings required by Order Nos. 1920 and 1920-A are a tool to implement the commission’s authority under FPA Section 206 and do not implicate public utilities’ rights and obligations under FPA Section 205,” FERC said. 

FERC issued Order 1920 and 1920-A under a Section 206 process that it initiated, which included a finding that its existing regional planning and cost allocation rules were unjust and unreasonable. The submission of compliance filings assists in implementing FERC’s authority under Section 206. 

“The express text of FPA Section 206 does not provide public utilities with statutory filing rights with respect to the just and reasonable replacement rate following a finding that existing rates are unjust, unreasonable, or unduly discriminatory or preferential,” the order said. “Rather, the authority to ‘determine the just and reasonable rate, charge, classification, rule, regulation, practice or contract to be thereafter observed and in force’ is vested in the commission, and — in commission-initiated proceedings under FPA Section 206 — the commission must find that the replacement rate it determines and fixes meets the statutory criteria.” 

The law does not preclude FERC from requiring transmission providers to file state cost allocation methods. And just because a public utility has to file a compliance filing does not transform that into a Section 205 filing. 

“A contrary conclusion would fail to recognize and give effect to the distinct and express statutory authority afforded to the commission in FPA Section 206, which arises pursuant to specific statutory findings and which, once triggered, is subject to different requirements than FPA Section 205 filings,” the order said. 

While Section 205 does give public utilities exclusive filing rights, when considered in the correct statutory context the arguments that require them to file state cost allocation agreements are not persuasive. 

“FPA Section 205 is not implicated by these aspects of Order No. 1920-A, and arguments to the contrary conflate compliance filings to assist the commission in implementing its authority under FPA Section 206 with public utilities’ rate filings under FPA Section 205,” the order said. 

Part of the debate goes to a court case from Atlantic City where FERC tried to require public utilities to cede their Section 205 filing rights to an RTO (PJM in the court case). The court found that FERC could not deny utilities statutory rights given to them by Congress. 

Order 1920 does not remove those filing rights, because the requirement to file state cost allocation agreements falls under FERC’s authority to set a replacement rate under Section 206. 

Transmission owners also made arguments that imposing the state filing requirements goes against the Administrative Procedures Act. FERC responded that given how important state engagement is to getting large, regional transmission lines built, it makes sense to ensure they have meaningful participation in the process. 

“The commission found that the additional requirement would allow it to better evaluate whether transmission providers have complied with Order No. 1920’s requirement to provide a forum for negotiations that enables meaningful participation by relevant state entities during the engagement period,” the order said. 

A group of PJM transmission owners argued the requirement goes against the First Amendment to the Constitution by compelling speech. 

“Order No. 1920-A imposes no actual burden or limitation on transmission providers’ speech but instead requires nothing more than the attachment of one or more files, containing the information provided by relevant state entities, to transmission providers’ compliance proposals under FPA Section 206,” the order said. 

Another item that transmission owners filed for rehearing was the requirement that regional planners consult state regulators before amending long-term cost allocation arrangements, making similar arguments about the FPA. 

FERC disagreed again, saying the consultation requirement does not regulate Section 205 filing rights but rather addresses the practices through which cost allocation methods are developed, which is tied to the likelihood such lines actually get built. 

“In Order No. 1920-A, the commission determined — and we here sustain — that requiring transmission providers to consult with relevant state entities will provide an opportunity for state input, which ‘has the potential to minimize additional costs and delays in the siting process and to facilitate the development of long-term regional transmission facilities,’” the order said. 

One area where FERC did tweak Order 1920 was to clarify that regional transmission plans can consider the needs of non-jurisdictional utilities if they voluntarily agree to pay their fair share under regional cost allocation.  

The National Rural Electric Cooperative Association and transmission owners in the WestConnect regional planning area argue the previous language could be interpreted to ban any planning around non-jurisdictional utility needs. 

If a non-jurisdictional utility has not voluntarily enrolled in a transmission planning region, its needs cannot be addressed. But if they have signed up for a region, then they can as long as the compliance filing can show FERC there is no free ridership issue.

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FERC Sustains Order Rejecting Expanded Susquehanna Co-located Load Arrangement

FERC sustained its rejection of amendments to the Susquehanna nuclear plant interconnection service agreement (ISA) to increase the amount of power serving a co-located data center (ER24-2172).

The changes sought by Talen Energy would have increased the scale of the Amazon Web Services data center operating behind the fence of Susquehanna from 300 MW to 480 MW. That was rejected by the commission on Nov. 1 on the grounds PJM had not demonstrated the proposal was “necessary for any interest unique to the interconnection of the Susquehanna customer facility.” (See FERC Rejects Expansion of Co-located Data Center at Susquehanna Nuclear Plant.)

The April 10 rehearing order defended the commission’s earlier finding that the proposed ISA amendments were not based on “specific reliability concerns, novel legal issues and unique factors” as demonstrated by it being based on PJM’s generally applicable guidance document for co-located configurations. While the RTO since has rescinded that document, the commission noted that portions of the proposed amendments to Susquehanna’s ISA mirrored the guidance and comments debating the proposal referred to it repeatedly. The rehearing order argued that allowing a standardized practice to be the basis of ISA language that does not conform to the pro forma interconnection service agreement (ISA) would weaken the commission’s necessary standard.

In its request for rehearing, Susquehanna said the commission’s rejection was not based on the unique configuration Talen sought, but rather that it could create a precedent for other resources that would not be reflected in the pro forma ISA. The company argued that being the first of its kind is not a valid reason for denying the application.

The commission wrote that reliance on the guidance document “raised the question of whether PJM intended to offer certain terms to all similarly situated interconnection customers.”

“Creating a requirement that the commission wait for a pattern to emerge before rejecting a non-conforming provision, as Susquehanna requests, would meaningfully weaken the necessary standard and meaningfully increase the possibility for disparate treatment that the necessary standard is designed to diminish,” the commission wrote.

Susquehanna also argued that reliability concerns “haunt” the rejection order despite PJM stating that necessary studies had not identified any issues with the configuration.

In the rehearing order, the commission wrote the study findings are not relevant to the rejection order, which hinged on a determination that PJM had not shown that the non-conforming language was necessary.

Vistra requested the commission clarify whether its rejection establishes a blanket limit on amending ISAs to co-locate data centers. If the intention was to hold that such amendments are not appropriate, Vistra said the underlying issues should be outlined so Susquehanna could refile without those provisions and others could do so as well. The commission responded that the rejection order does not prejudice any future co-located load configurations.

Phillips Dissents

The rehearing order was approved on the same lines as the original rejection, with Commissioners Mark Christie and Lindsay See in support and Willie Phillips dissenting. Commissioners David Rosner and Judy Chang did not participate.

Phillips wrote that he’s hopeful the commission’s order that PJM show cause investigating whether PJM’s tariff is just and reasonable without language addressing co-located load will allow such configurations to proceed. He repeated arguments he made opposing the original rejection that data centers represent an “era defining technology” that requires regulatory leadership. (See FERC Launches Rulemaking on Thorny Issues Involving Data Center Co-location.)

“Notwithstanding my disagreement with these orders’ rationale and determination, I remain hopeful that the Commission’s recently issued order … will soon result in solutions to address what I regard as unnecessary roadblocks to the continued maturing of an industry that is vital to our economic prosperity and national security,” Phillips’ dissent on the rehearing order said.

PJM’s response to the show cause order said more FERC guidance is needed on how the RTO should allow co-located configurations to proceed and laid out several possible pathways. It also noted challenges that remain unsolved, such as how to account for ancillary services the RTO maintains are consumed by co-located loads and whether protective schemes can be adequate for preventing the load from inappropriately taking energy from the grid. (See PJM Responds to FERC Co-located Load Investigation.)

Proponents of co-location have argued that in some instances the load should be considered separate from the wholesale grid and should not be charged for services such as regulation and black start.

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Urgent EDAM Congestion Revenue Issue ‘Will Take Time’ to Address

The complex issue regarding congestion revenue allocation in CAISO’s Extended Day-Ahead Market (EDAM) continues to raise questions and cause some confusion for market participants, with a market expert reviewing possible solutions at an April 8 Western Energy Markets Governing Body meeting.

The issue is whether certain congestion revenues should be allocated to the balancing area in which the congestion costs accrued, or to the neighboring EDAM balancing authority area where the transmission constraint is located, specifically in cases in which parallel — or loop — flows occur.

In March, CAISO launched an “expedited” initiative to address stakeholder concerns. The ISO plans to release a full proposal on the issue in the coming week. (See Fast-paced Effort will Address EDAM Congestion Revenue Issue.)

Under current EDAM market rules, Open Access Transmission Tariff (OATT) customers in one BAA will end up paying costs for congestion for parallel flows caused by binding transmission constraints in neighboring BAAs, CAISO market expert Susan Pope noted during the meeting. This requirement could make a system and its transmission users carry the costs of unexpected congestion.

OATT point-to-point (PTP) service is awarded without fully accounting for parallel flows, while management of infeasible OATT schedules today requires approaches such as curtailment of non-firm service and out-of-merit redispatch by the impacted BAA to manage congestion, Pope said.

“These congestion charges only occur when there are flows over binding constraints and the amount of the charges reflect the cost of managing the congestion on those constraints,” Pope said. “So, if the cost of managing the congestion isn’t that big, the charges aren’t going to be that big.”

There is strong justification for charging OATT customers for EDAM congestion costs, because the charges are tied to the marginal cost of redispatch to manage congestion on the binding constraints impacted by the OATT schedule, Pope added.

At an April 2 meeting on the subject, Anna McKenna, CAISO vice president of market design and analysis, also disputed the contention that EDAM’s existing congestion revenue framework is inherently flawed. (See EDAM Congestion Debate Builds Even as CAISO Moves to Address Issue.)

However, Pope said the ISO could address stakeholder concerns by redesigning EDAM to include an avenue for OATT customers to more fully hedge or otherwise manage EDAM congestion cost charges.

More specifically, EDAM could adopt use of congestion revenue rights (CRRs), which would provide OATT customers with a hedge against EDAM congestion charges. But the market design does not include CRRs, and CAISO would need to address core issues prior to including them, Pope said. Introducing CRRs would require new rules to establish transmission capability for CRRs while also enabling cost recovery for transmission service providers, she said.

In many RTOs and ISOs, such as NYISO, PJM, MISO and CAISO, OATT transmission reservations were infeasible when modeled, according to Pope’s presentation. Furthermore, RTOs with CRRs have required lengthy stakeholder processes to design the market rules for converting existing OATT service arrangements into CRR allocations, Pope said.

Despite these challenges, introducing CRRs for hedging EDAM congestion costs would “likely enable more efficient scheduling and decrease the cost of serving EDAM load,” Pope said. “But it will take time to design and implement CRRs when agreed upon by EDAM participants.”

In the meantime, a transitional approach is needed to address concerns about OATT transmission customers’ potential undue exposure to charges for parallel flow on binding constraints in other BAAs, Pope said.

One transitional solution is to enable PTP customers to “opt out” of EDAM settlements, which could allow them to avoid congestion charges under all grid conditions, such as by self-scheduling rights before or after EDAM without paying congestion charges, Pope said. But this approach could reduce efficiency and customer cost savings from EDAM and make it more difficult to maintain system reliability during stressed system conditions.

More Work Ahead

WEM Governing Body member John Prescott said the parallel flow congestion issue is “a very thorny problem.”

“But I appreciate the fact that everybody is rolling up their sleeves and, I hope, working in earnest to solve this problem,” Prescott said.

At the meeting, Alan Meck, principal market design analyst at Pacific Gas and Electric, asked if CAISO could break down the pros and cons of each possible solution to the matter.

“I think that I’m following this presentation, but it’s been kind of difficult,” Meck said. “It would be really helpful, I think, if you could add one additional slide synthesizing EDAM design pros and cons and where all of these different issues shake out.”

Pope reminded attendees that a good solution to the issue “is probably one that doesn’t make anybody happy.”

“If everybody’s complaining about something, that might be a good solution,” Pope said. “There’s a lot to gain by solving this problem. I just wanted to encourage everybody to sort of work together, be realistic and try to craft solutions.”

CAISO is on track to publish a full proposal on the topic on April 14, spokesperson Jayme Ackemann said. Whether the CAISO Board of Governors will vote on the proposal at its May meeting is still under consideration, she said.