INDIANAPOLIS — MISO avoided maximum generation alerts and events this fall despite dealing with record-breaking temperature swings in its southern footprint.
The RTO’s nearly 107-GW fall peak on Sept. 11 was “well below” the forecasted 112-GW peak for the season, MISO Executive Director of System Operations Renuka Chatterjee reported to the Markets Committee of the Board of Directors on Tuesday. This year’s fall peak also paled compared with 2018’s almost 115-GW record.
Real-time prices were likewise down, averaging $25/MWh, a 23% decrease year-over-year. Chatterjee put lower prices down to “surging” natural gas production.
However, the modest peak and prices belie the volatility in fall temperatures, with hot weather alerts in the southern parts of the footprint in early September and October, followed by a cold weather alert by mid-November.
“Both of these weather events brought record-setting temperature swings in our footprint. I’ve heard that close to 100 temperature records were broken,” Chatterjee said of a hot weather alert Sept. 5-9 and a cold weather alert Nov. 12-13, both in MISO South.
MISO President Clair Moeller said operations teams showed “exemplary” performance in handling both situations.
Chatterjee said “unseasonably extreme cold” settled in the Central and South regions during the November event. “If these temperatures happened in January, we wouldn’t be talking about them,” she said.
She said MISO control room employees were busy managing congestion and responding to outages on Nov. 13.
MISO was able to avoid issuing a maximum generation event this fall, though Chatterjee said conditions in MISO South would have warranted it for about 30 minutes on Nov. 13.
“In hindsight, we could have issued that notification for a short time,” Chatterjee said.
MISO Independent Market Monitor David Patton called the conditions on Nov. 13 “bizarre.” He said Little Rock, Ark., registered at 19 degrees, about 30 degrees below normal. He also said a large MISO South generator kept delaying its start time during the day, losing out on roughly $1 million worth of payments in the process and complicating the supply picture.
Patton also said his staff is still investigating a request from SPP to cut MISO flows on the regional dispatch limit that day to 1,500 MW, resulting in additional congestion costs of $876,383 to MISO. MISO neighbors Southern Company and SPP were also facing challenging supply conditions Nov. 13, Patton said.
“What happens when we derated this, not only did it cost MISO and its customers a lot of money, but it also caused MISO to violate a constraint in MISO South,” Patton said.
Patton said if MISO were granted “better visibility of neighbors’ constraints” in real-time, it might have been able to provide targeted relief instead of simply following SPP orders to “massively derate” the flows.
Patton said MISO operators likely didn’t have an appropriate amount of time to react to SPP’s request.
“MISO was put in the position of having to derate the [Regional Dispatch Transfer] and wasn’t able to offer alternative solutions. When they’re asked to derate due to reliability concerns, you have to,” Patton explained.
“This has seemed to blow the cover off areas that we don’t have much progress on. We don’t have visibility into our neighbors’ decisions, and they might not have visibility into our decisions, and that’s costing economic decisions,” MISO Director Barbara Krumsiek said.
Patton also said he continues trying to convince MISO’s transmission operators to adopt dynamic transmission line ratings. He also said MISO should “more actively” validate transmission ratings. He said the suggestion would likely make it into his 2019 State of the Market Report.
MISO Enters Winter
Chatterjee said MISO continues to expect a 104-GW winter peak, with about 115 GW worth of resources on hand to mitigate it. She said MISO is especially concentrating winter preparations on outages. Over the last five years, MISO experienced an average 27 GW worth of generation outages on monthly peak hours December through February.
Moeller said many of the outages occur in MISO’s older, steam generation.
“We’re seeing outages of the older, steam fleet continue. In many cases, they’re aging so [operators see] no reason to put money in them,” Moeller said.
Additionally, MISO in November began publishing a first edition of its multiday operating margins, which predicts supply conditions six days in advance. The multiday forecast is for informational purposes only and is not a multiday financial market.
Advanced meters now represent more than half of the electric meters in service, but the growth of demand response has been choppy due to slow adoption of time-of-use rates, FERC reported Wednesday.
The U.S. had 78.9 million advanced meters operational in 2017, 51.9% of the total of 152.1 million meters and an increase of five percentage points from 2016, FERC reported in its 14th annual report on DR and advanced meters. The annual report was mandated by Congress in the Energy Policy Act of 2005.
Between 2007 and 2017, the number of advanced meters in operation jumped almost twelve-fold and now dominate in five NERC regions: Texas RE (90%); SPP RE (63%); the Western Electricity Coordinating Council (61%); the former Florida Reliability Coordinating Council (58%) and ReliabilityFirst (55%).
Advanced meter growth (2007–2017) | FERC, Energy Information Administration, Institute for Electric Efficiency
In the last year, FERC reported, utilities in Arkansas, Hawaii, Indiana, Minnesota and New Jersey have proposed or received approval for deploying advanced meters, seeking to improve customer engagement, reduce outage duration and create a foundation for other grid modernization efforts.
Commission staff noted regional differences in advanced meter penetration, with residential customers at higher penetration levels than commercial or industrial customers in most regions. In FRCC, Hawaii, the Midwest Reliability Organization and the Northeast Power Coordinating Council regions, however, advanced meter penetration is highest in the industrial sector.
Overall, advanced meter penetration rates for residential and commercial customer classes were at or above 50% for the first time in 2017, while penetration for industrials grew to 44.5%.
Time-of-Use Rates
But while advanced metering has become more ubiquitous, policymakers have been slow to embrace the technology’s capabilities. The report identifies the “relatively slow implementation of time-based rate programs” as a main cause of lackluster customer participation in demand response.
Nationwide, enrollment in time-of-use (TOU) rate programs has increased by 42% since 2013, with retail customer enrollment increasing by about 7% in 2016/17. But only 8.5 million customers nationwide have TOU rates, 75% of them in ReliabilityFirst and WECC.
Penetration rate and number of advanced meters by region (2013–2017) | FERC
Regulators in New York and North Carolina have ordered their utilities to expand time-based rates to reduce peak demand and leverage their metering investments. Regulatory commissions in Maryland, Michigan, Minnesota, and the District of Columbia have adopted or are exploring time-based rates for electric vehicles to incentivize charging during off-peak hours.
Demand Response
Demand response statistics showed some advances and some retreats.
Potential peak demand savings from residential programs — the total demand savings that could occur at the system peak hour if all demand response was called — dropped by 12% to 31,508 MW from 2016 and 2017, with the biggest reductions in SPP RE (due to lower reported savings by Oklahoma Gas and Electric) and WECC (with large decreases reported by Salt River Project and Southern California Edison). The report said the drop in WECC “likely reflects a shift toward greater demand response participation in CAISO’s wholesale market.”
Demand response participation in the wholesale markets increased by about 8% from 2017 to 2018, to a total of 29,674 MW, with the biggest increases in CAISO and MISO but decreases in ISO-NE and PJM, which have tightened requirements for capacity resources. The registration of DR in wholesale capacity, energy and ancillary services markets grew to 6% of peak demand in 2018.
Potential peak demand savings (MW) from retail demand response programs by region (2013–2017) | FERC
ISO-NE reported a 48% drop in DR participation from 2017 to 2018, which the report noted “coincides with the implementation of ISO-NE’s Pay-for-Performance program, which places more stringent requirements on [capacity] resources,” including DR.
PJM reported a net decrease of 226 MW (2.4%) in DR enrollment from 2017 to 2018, which the commission said “may be due to the continued phasing out of legacy demand response products” as the RTO completed its transition to an annual Capacity Performance product with tougher penalties for non-performance.
ERCOT, MISO, CAISO and PJM each deployed emergency demand response in 2019:
ERCOT reduced load by about 3,100 MW on Aug. 13 and 1,800 MW on Aug. 15 by deploying emergency response service (ERS) after high demand, reduced wind production and generation outages left the region short of its 2,300-MW reserve threshold. (See ERCOT Survives Another Dayin the Roaster.)
MISO activated load modifying resources (LMRs) on Jan. 30, during an energy emergency alert Level 2 emergency in its Central and North regions. The RTO’s market monitor predicts DR will be deployed more frequently as the region’s capacity surplus decreases. (See MISO Maintains Reliability Through Arctic Midwest Temps.)
CAISO issued a statewide “flex alert,” calling for voluntary conservation on June 11, and some utilities declared critical peak pricing days — boosting prices temporarily — for retail customers several times during the summer.
PJM called on interruptible customers in the American Electric Power, Baltimore Gas & Electric, Dominion and Potomac Electric Power Co. zones to reduce load on the afternoon of Oct. 2, when the RTO’s demand exceeded 126,000 MW, its second-highest October demand on record.
FERC on Tuesday approved Tariff revisions refining ISO-NE’s rules for conducting competitive transmission solicitations, a process that may be tested for the first time this month (ER20-92).
The changes increase the information to be provided by transmission developers and provide more detail on the evaluation criteria the RTO will use.
ISO-NE plans to issue its first competitive transmission solicitation — for solutions to non-time sensitive needs identified in its 2028 Boston Needs Assessment Update and Needs Assessment Addendum — as soon as this month. The request for proposals (RFP) will address transmission facility overloads under peak load conditions in the Boston area and system restoration concerns with the underground cable system in the area. (See “Needs Update Reduces Thermal Violations” in ISO-NE IDs $8.7M Tx Fix for Boston Area.)
115-kV transmission and above in Boston area | ISO-NE
Two-Step Process
The RTO will use a two-step process, with developers first submitting plans describing a project’s interconnection to the existing transmission system, estimated costs, financing and any cost containment measures.
ISO-NE will review the proposals, with input from the Planning Advisory Committee (PAC), to ensure they address the identified needs and are feasible and cost competitive. The RTO will then identify finalists who will be required to provide additional details to guide its selection of the preferred solution.
The RTO also created a new pro forma agreement between it and the selected qualified transmission project sponsor (QTPS) spelling out the development, design and construction of the project, including project milestones, status reports and cost containment measures. The RTO’s agreement is modeled on the designated entity agreement PJM uses in its competitive transmission solicitation process.
The changes also include a clause allowing the RTO to cancel an RFP if new assumptions modify or eliminate the identified need.
Outside the Scope
The commission dismissed as outside the scope of the proceeding the Connecticut attorney general’s protest arguing that while the RTO’s proposals are an improvement, they are insufficient to ensure truly competitive procurements and thus not compliant with Order 1000. The AG contends the process does not adequately consider non-transmission alternatives (NTAs), such as battery storage and transmission line ratings, and asked the commission to order RTOs to report annually or biannually on their adoption of NTAs or other grid management options.
The Massachusetts Attorney General asked FERC to determine ways to improve the ability of NTAs to compete with traditional transmission solutions.
Transmission developer New England Energy Connection (NEEC), an affiliate of LS Power, asked the commission to encourage ISO-NE to establish a stakeholder process to address broader issues in the competitive solicitation process after the 2019 RFP.
NEEC said an “over-reliance on the immediate need designation” is a significant factor in the lack of competitive windows in New England to date and the region should consider replacing its sponsorship model with competitive bidding.
FERC said the Massachusetts and Connecticut proposals were outside the scope of the proceeding because the proposed Tariff changes don’t address NTA participation.
“Although we find that NEEC’s request to encourage ISO-NE to establish a stakeholder process to address broader issues in the existing transmission competitive solicitation process is also outside the scope of this proceeding, we note ISO-NE’s intention to hold stakeholder discussions following the 2019 RFP to consider additional changes to the competitive solicitation process,” FERC wrote.
ISO-NE spokesman Matt Kakley said the RTO does not have a firm date for release of the RFP, “though we are hoping to get it out this month.”
AUSTIN, Texas — Beth Garza announced Tuesday she will step down as director of ERCOT’s Independent Market Monitor, a position she has held since 2014.
Garza broke the news during her bimonthly report to the ISO’s Board of Directors, telling stakeholders, “My time as director of the IMM has come to an end.”
She told RTO Insider it became evident to her that Texas’ Public Utility Commission, which has oversight of the IMM, wanted someone else to fill the director’s position.
“I support the commission’s decision to have the IMM director they want,” she said. “I’m disappointed that I’m not the person for that role.”
The PUC, ERCOT and Potomac Economics, Garza’s employer for 11 years, are all parties to the IMM’s contract. However, that four-year contract expires at the end of the year.
The PUC requested proposals for a new contract and is currently in negotiations, with the hope of reaching an agreement before the end of year, said Andrew Barlow, the commission’s external affairs director. Potomac Economics is among those bidding for the new IMM contract.
Garza said the PUC would be “willing” to award the contract to Potomac Economics but with the understanding she needed to be replaced. She hinted at disagreements between the PUC and the IMM.
“There’s a built-in tension between the commission’s role to provide oversight and direction to the IMM and the IMM’s role to provide independent analysis,” Garza said. “That tension interacts squarely at the director’s position.”
ERCOT directed media inquiries to the PUC, which did not offer comment beyond Barlow’s.
Potomac and Garza have been fierce advocates of real-time co-optimization. The PUC earlier this year directed ERCOT to implement the market tool, which procures both energy and ancillary services every five minutes to find the most cost-effective solution for both requirements.
Garza said she would remain at Potomac in a non-public role.
The Washington, D.C.-based firm also provides market monitoring for ISO-NE, MISO and NYISO.
PJM said it was a quiet operations month in November with zero spinning events, nine post-contingency local load relief warnings (PCLLRWs) and one reserve sharing event with the Northeast Power Coordinating Council (NPCC).
The load forecast error came in at 2.22% — well below the 3% margin and a far cry from the unsolved load deviation witnessed during the first two days of October. (See “DR Load Forecast Error Unsolved” in PJM OC Briefs: Nov. 12, 2019.)
PJM’s 2019 Load Forecasting Error margin (Achieved 80% of the time)| PJM
Fall Restoration Drills
PJM said its fall restoration drills conducted between Sept. 25 and Oct. 30 went well, with only minor complaints about the simulator and event duration.
Some 143 companies and 52 PJM operators participated. All of the RTO’s nuclear plants received off-site power under the four-hour deadline with one exception, due to simulator issues.
Companies said the drill should last two days and requested more practice on cross-zonal procedures. The simulator itself took some getting used to, Brian Lynn told the Operating Committee on Tuesday.
The spring drills are scheduled for May 19 and May 20.
Manuals Endorsed
The committee endorsed:
Manual 38: Operations Planning — Periodic review to conform NERC standard references, remove the PJM-NYISO seasonal operating study and update Attachments A and B.
Manual 14-D: Generator Operational Requirements — Remove references to PJM’s Tariff regarding the definition of “generating facility.” The term is not defined in the Tariff, pending a ruling on FERC Order 845 compliance.
ST. PAUL, Minn. — Below is a summary of actions taken at the Midwest Reliability Organization’s (MRO) Annual Member and Board of Directors Meeting last week.
Revised the name of the Organizational Group and NERC Representative Oversight Committee to Organizational Group Oversight Committee.
Updated Policy and Procedure 1 regarding MRO Independent Directors’ removal of outdated language. It also raises the annual retainer from $56,500 to $79,625 while eliminating the $6,000 annual retainer per committee.
Revised MRO’s General Finance Policies to define intangible assets and the procedure for carrying them on the balance sheet. The change was suggested to all regional entities by NERC, with the goal of encouraging a low debt-to-asset ratio.
In addition, members voted to appoint Lam Chung — currently vice president and engineer of strategy, innovation and finance – as treasurer, thrift savings plan trustee and corporate compliance officer effective Dec. 5, replacing Ken Gartner. The Board of Directors agreed to elevate current Vice Chair Thomas Kent from Nebraska Public Power District to Chair effective Jan. 1, replacing Silvia Mitchell of NextEra Energy. Kent’s role will be filled by Brad Cox of Tenaska Power Services.
MRO Praised for Security Work
NERC Chair Roy Thilly praised MRO for taking a proactive approach to security, singling out the Security Advisory Council (SAC), established this year, as a particularly valuable resource. The SAC advises MRO’s Board of Directors, staff and registered entities on cybersecurity; physical security; and SCADA, EMS, substation and generation control systems; and promotes awareness of these subjects.
The SAC’s information-sharing functions are of particular interest to NERC, given the decision earlier this year to merge NERC’s Operating, Planning and Critical Infrastructure Protection committees into a new panel, tentatively called the Reliability and Security Technical Committee (RSTC). (See NERC Board OKsCommittees Merger.) A group like the SAC can help to fill any gaps left by the dissolution of the existing committees while the new group starts up, Thilly said.
“I get feedback from [NERC CEO Jim Robb] and from the [Electricity Information Sharing and Analysis Center] that they really like that model as a way of engaging the regions on the cyber issue, which has been difficult,” said Thilly. “I know Jim would like to see [that model] replicated in the other regions. So, thank you for that, and help us do that because with CIPC going away, there’s a forum function and information sharing function … that need to be captured.”
McMullen Honored on Retirement
MRO CEO Sara Patrick called on members to recognize Michael McMullen, the director of regional operations at MISO, who will retire this year after 13 years of service. McMullen was the inaugural chair of MRO’s operating committee and currently serves on the Reliability Advisory Council, formed earlier this year. In addition, he has served on several technical committees and groups at NERC.
“He was instrumental in standing up the operating committee and remained a committee member, providing leadership and technical guidance, for its eight-plus years of existence,” Patrick said. “We sincerely appreciate Mike’s dedication and contributions to the success of MRO and reliability of the bulk power system.”
Thanking the members for their recognition, McMullen said it was a pleasure to have served in MRO and he was confident in the organization’s work going forward.
“I think my biggest vote of confidence is that in my next stage, I do not own a generator and I do not plan on getting one,” McMullen said. “I know that we’ll remain reliable.”
MRO’s next board meeting will be held in St. Paul on April 1-2.
LAS VEGAS — Stakeholders in CAISO’s Western Energy Imbalance Market last week reacted coolly to a proposal by Utah’s Deseret Power Electric Cooperative to tighten the market’s rules on transmission feasibility.
Deseret made the proposal during a Dec. 3 Regional Issues Forum panel that explored the differences between resource sufficiency and resource adequacy.
Don Tretheway, CAISO’s senior adviser for market design, said the difference is mainly timing.
“Resource adequacy is ensuring, on a forward basis, that you’ve contracted with sufficient steel in the ground so that you can meet your monthly peaks, your annual peaks. It’s really about … making sure that you can serve your load,” Tretheway said. “Resource sufficiency evaluations [are] a series of tests to ensure that someone’s not inappropriately leaning on an energy imbalance market [to meet demand] on a short-term basis.”
Four tests are conducted several times per hour to ensure an entity has met the agreed-upon threshold for participating in the EIM, Tretheway said, including a transmission feasibility test to determine if a participating entity has sufficient transmission capacity or unresolved transmission congestion. A balancing test determines if an entity’s actual load is within 5% of its base-schedule load for that hour, according to the ISO. A capacity test makes sure an entity has sufficient resources to meet its projected load, and a ramping test looks at ramping flexibility in 15-minute increments.
Clay MacArthur, vice president of power marketing at Deseret, said the EIM should adopt rules to address a loophole in the feasibility test that may allow entities to inappropriately spread around (socialize) the costs of congestion.
The transmission feasibility test, he said, determines if electricity can reach load within a particular balancing area. “It’s just a simple test that looks for congestion on the system,” he said.
The EIM’s design allows for the socialization of unforeseen congestion constraints within a given hour, but MacArthur said that’s not the problem. The feasibility test, he said, doesn’t account for an entity that knows it has transmission constraints but fails to report them ahead of time.
“They can just submit a base schedule that ignores that,” MacArthur told RTO Insider.
If an EIM entity knows of transmission constraints and includes them as part of its base schedule, it will bear the costs, MacArthur said. But if it doesn’t report its pre-existing constraints, the EIM’s market design can inadvertently shift the costs of those constraints to other load-serving entities across the market via neutrality charges. “If my schedules were balanced and somebody came into the hour with a known transmission infeasibility, why should I pay a share of that?” MacArthur said. “I can’t do anything to mitigate that.”
He proposed tariff language requiring EIM entities to “ensure that all financially binding base schedules submitted to the market operator are feasible and do not violate any known or expected transmission constraints.”
If they do, then the EIM would be required to notify the entity and give it a chance to revise its base schedule. If the entity doesn’t, then it may be subjected to congestion offset charges, the proposal says.
MacArthur called for greater market transparency by releasing suffiency test results and neutrality charges to market participants. That would allow for an objective evaluation of whether the market has a problem, he said.
MacArthur said he just meant “pass or fail” and “ones and zero,” without divulging privileged information.
His proposal prompted sometimes heated discussion between panelists and audience members, though not much agreement with MacArthur’s proposal.
Kelcey Brown, PacifiCorp’s manager of market and analytics, acknowledged her company had been a party to the problem described by MacArthur during the EIM’s early years, after starting operations in 2014, when utilities were still going through a learning curve. But she said the company put safeguards in place to ensure it wouldn’t happen again. She said she didn’t know of other examples.
“I’m not sure this is as big of an issue as Clay is referring to,” Brown said.
Petar Ristanovic, CAISO vice president of technology, agreed. “I don’t understand your concern, sir,” he told MacArthur.
MacArthur said the only way to determine the problems’ extent would be to have the information he’d asked for.
For about 30 minutes, panelists and audience members held a back and forth, trying to clarify or argue points.
At the end of the panel, Pam Sporborg, the new chair of the RIF, thanked the panelists “for a lively discussion,” and the audience responded with hearty applause.
MacArthur said that as the transmission customer of an EIM entity, Deseret couldn’t formally request further proceedings. CAISO could do that on its own, he said, or Deseret could file with FERC.
“That may be the only way to get it addressed,” he said.
VALLEY FORGE, Pa. — PJM Board of Managers Chairman Ake Almgren recognized fellow board member and interim CEO Susan Riley for her efforts to lead the RTO during a “challenging” season, telling the Markets and Reliability Committee on Thursday her work will continue under her successor, Manu Asthana.
“We are very excited to welcome Manu as our new president and CEO,” Almgren said. “He brings many decades of experience from the electric industry. Some were different experiences, but very relevant experiences. We are confident in his leadership moving PJM forward.”
Riley will resume her role on the board once Asthana arrives next month and will help ensure a smooth transition, some six months after former CEO Andy Ott resigned.
“Overall, I’m proud of the progress PJM has made to build stronger relationships with constituents, built on common respect and listening,” Riley said. “I know this great work will continue under Manu, and the board is anxious for him to start.”
FTR Vote Deferred
The MRC deferred voting on the first round of financial transmission rights credit-related policy changes after some stakeholders expressed concerns about the ripple effect the revisions may have on market design.
PJM said the recommendations, initially presented at the October MRC, will improve its credit risk policies after the Financial Risk Mitigation Senior Task Force delegated a more holistic FTR market review and possible design changes to a separate Market Implementation Committee task force. (See “FTR Market Rule Changes,” PJM MRC Briefs: Oct. 31, 2019.)
One change includes hosting five long-term FTR auctions a year, instead of three, in order to increase oversight and visibility into portfolio conditions so that more collateral can be collected if necessary. A second would alter the structure of Balancing of Planning Period auctions so that participants can buy and sell in any month of the year, rather than being limited to a specific quarter.
The PJM Industrial Customer Coalition (ICC) and the Consumer Advocates of PJM States (CAPS), however, said their longstanding concerns about increasing the auction frequency still stand.
“We think the monthly change bleeds into the market design element,” the ICC’s Susan Bruce said. “We’ve not fully thought through the impact of FTR underfunding. If we don’t have good information on transmission outages, we have concerns that it may affect underfunding and it may have implications for market design.”
“The advocate offices had very similar concerns,” said Greg Poulos, executive director of CAPS. “This is one item that has a little bit of impact on market design, something that consumer advocates have been asking to be reviewed since last year when the GreenHat [Energy] investigation was going on.”
PJM Chief Risk Officer Nigeria Poole Bloczynski reiterated that the independent GreenHat investigation recommended these very changes and said the task can revisit the issue, if needed.
“This is not a one-stop shop,” she said. “We will continue to make improvements.”
Riley chimed in, urging stakeholders to find consensus, saying, “If we could get to ‘yes’ on this, it would be a really big win.
“We thought long and hard about design changes versus credit changes,” she said. “I agree this straddles the two. I understand the concerns. Voting in favor of the increase in auctions enables better credit management. … It doesn’t mean that a review of this can’t be a part of market design changes that we consider.”
The MRC will reconsider the changes at its Dec. 19 meeting.
End of Life Issue Charge Endorsed
American Municipal Power and Old Dominion Electric Cooperative scored a big win on Thursday after stakeholders in a sector-weighted vote of 3.83 to 1.17 endorsed their joint problem statement and issue charge exploring end-of-life determinations.
While stakeholders rehashed a familiar debate before casting their votes over where PJM’s role in supplemental project planning should begin and end, the committee ultimately approved formalizing the discussion. (See Competitive TOs Push Against PJM Supplementals and “Stakeholders Mull Tx Asset Management Discussion,” PJM MRC Briefs: Oct. 31, 2019.) None of the 11 TOs voting endorsed the issue charge, according to PJM’s tally.
The MRC will continue working on the issue and recommend approval for any necessary governing document changes at its March meeting.
Comparative Cost Framework, Opportunity Cost Calculator in Flux
The MRC did not endorse revisions to the opportunity cost calculator or hear another first read of its pending comparative cost framework.
In the former issue, main motion sponsors Dominion Energy and Panda Power Funds are working toward a single-package compromise with PJM. (See “Opportunity Cost Calculator,” PJM TOs Wary of Cost Containment Rules.)
Real-time Values, Parameter-limited Schedules
Some capacity generators use real-time values (RTVs) to override unit-specific parameters for inappropriate reasons, PJM contends, causing unnecessary confusion during dispatch.
The original intent of RTVs was to provide a way for generation operators to communicate current operating capability to PJM if their resources couldn’t meet their unit-specific parameter limits or approved exceptions. Generators opt to use RTVs and forfeit operating reserve credits and make-whole payments as a result.
Except, some generators consistently use RTVs to increase notification time on parameter-limited schedules “to reflect the decision not to staff the resource during hours they project the resource will not be economic,” PJM said in a problem statement. The operational impacts mean that resources called in real-time based on their schedules cannot perform as expected.
PJM suggested a special session of the MIC to commence in 2020 to study the problem and recommend solutions.
Manual 03A: Energy Management System Model Updates and Quality Assurance — revisions stemming from a cover-to-cover periodic review and is phase one of an effort to update, reorganize and streamline the manual’s content.
Manual 13: Emergency Operations — revisions to incorporate the 2020 day-ahead scheduling reserve requirement.
Manual 15: Cost Development Guidelines — revisions that clarify that market sellers can only change the format of maintenance adders ($/MMBtu, $/MWh or $/start) during the annual review period for energy offer components. (See “Manual 15 Clarifications on VOM Costs,” PJM MIC Briefs: Nov. 13, 2019.)
PJM Manual 19: Load Forecasting & Analysis — a periodic review and documentation of the long-term load forecast.
Operating Agreement revisions that clarify the requirements for sharing forecasted unit commitment data to TOs for reliability studies.
Non-substantive changes to the Tariff, OA and Reliability Assurance Agreement that standardize cross references in all three documents.
Members Committee Elections
Members Committee Chairman Chuck Dugan, of East Kentucky Power Cooperative, led his last meeting Thursday before Vice Chair Steve Lieberman, of American Municipal Power, takes over next year.
Katie Guerry of Enel X will assume the role of MC vice chair. Brian Kauffman, also of Enel X, will take over as whip for the Other Supplier sector. Members also re-elected all existing whips, including:
Susan Bruce, PJM ICC, End Use Customers
Adrien Ford, Old Dominion Electric Cooperative, Electric Distributors
Michael Borgatti, Gabel Associates, Generation Owners
Sharon Midgley, Exelon, Transmission Owners
Load Management Test Rules
PJM’s new load management testing rules became official on Thursday after receiving endorsement from the MC.
In October, the MRC endorsed new load management and price-responsive demand testing rules for Capacity Performance resources after PJM said old measures failed to mimic real-life emergency procedures. (See PJM Stakeholders Support More Realistic DR Testing and “Stakeholders Urge Consensus on Load Management Testing Requirements,” PJM MRC/MC Briefs: Sept. 30, 2019.)
The new rules, effective with the 2023/24 delivery year, would give PJM authority over scheduling tests — instead of the resource itself — and provide advanced notification so participants can prepare. The changes would implement a three-step system that gives resources first notice of an upcoming test one week prior to the two-week testing window, with additional alerts by 10 a.m. the day before and the day of the scheduled test. There will be one test per year when there is no event, with half of resources tested in winter and the other half in summer.
Critical Infrastructure Resolution
Growing concerns over a pending Tariff attachment proposal from TOs that would create a new, confidential process to mitigate critical infrastructure reached a crescendo on Thursday when LS Power presented the first read of an advisory against the proposal.
Sharon Segner, vice president of LS Power, said her company believes the attachment conflicts with the OA because it will move forward without any vetting from the MC.
“We can’t veto or delay, but we can offer an opinion,” Segner said of the advising document. “It’s a voice that says the issues with the OA haven’t been addressed.”
At the heart of Segner’s argument is a belief that incumbent TOs don’t get exclusive rights to handling critical infrastructure on NERC’s CIP-014 list. Because the projects could carry significant regional implications, LS Power believes PJM should plan their mitigation. (See PJM TO Filing Stirs Up Transparency Concerns.)
“My company stands on the side of PJM,” she said. “My company believes that PJM is a world class transmission planner and, as a result of that, when it comes to national security, we believe PJM should be in charge.”
Incumbent TOs argue that NERC’s confidentiality standards — and their rights under PJM’s Attachment M-4 process — support their intention to file the mitigation plan at FERC without input from other sectors.
“There is no inconsistency between Attachment M4 and the OA,” said Pulin Shah, director of transmission strategy and contracts for Exelon. “The M4 process is not permanent. It will sunset in five years. There is a compelling need to move forward to address the loss of these substations.”
PJM maintained its neutrality in the debate and reiterated that all stakeholders agree about mitigating critical assets so they are no longer vulnerable to attack. (See PJM Remains Neutral in CIP-014 Debate.)
WASHINGTON — Last week was a busy one for the Solar Energy Industries Association.
The trade association held its annual policy summit at the Washington Plaza Hotel on Wednesday, on the eve of both the International Trade Commission’s midterm review of the Trump administration’s tariffs on imported solar panels and a Court of International Trade ruling affirming the exemption of bifacial modules from the tariffs.
On Thursday morning, SEIA held a rally outside of the trade commission’s headquarters in D.C., calling upon “solar workers, advocates and anyone passionate about fair solar trade policy” to attend and show support for ending the tariffs.
But Wednesday’s summit acted as a rally of sorts as well, as the solar investment tax credit expires at the end of this year, and legislation to extend it faces stiff competition for congressional attention amid impeachment proceedings and a Dec. 20 deadline to fund the government.
SEIA President Abigail Ross Hopper and keynote speakers urged attendees to be more active in contacting their representatives in Congress, particularly if those representatives are Republican.
The event opened with a speech from U.S. Sen. Catherine Cortez Masto (D-Nev.), who in July introduced the Senate version of a bill that would extend the tax credit for another five years. (The House version was introduced by Rep. Mike Thompson (D-Calif.)
“I need your help,” she said. “I need your help with some of my colleagues on the other side of the aisle. … Just make the call, if you haven’t already. They don’t need to publicly sign onto to the bill. … Just ask them to reach out to Mitch [Senate Majority Leader Mitch McConnell (R-Ky.)] and tell him why this is so important; why this needs to be passed; why this needs to be part of the package at the end of the day.”
Hopper echoed Cortez Masto’s call to action before she began her own speech, noting that she has found people in the industry to be timid when it comes to calling their representatives.
Many of the panels that followed focused on the best ways to lobby Republicans on solar energy policy. Speakers told their own success stories and described the gradually changing political landscape around renewable energy and climate change as encouragement for attendees.
Brandon Audap, vice president of government relations for Citizens For Responsible Energy Solutions, spoke about his efforts to lobby Republicans on climate change. His organization focuses only on trying to convince the GOP to enact “responsible, conservative solutions” to solve the problem.
As SEIA’s former director of federal affairs, Audap worked on the first tax credit legislation. Though “Republicans are more engaged on climate change,” there is no unified party stance on it, so his organization has had to canvas every elected official in Congress (250) individually, he said.
The good news for the industry: “The era of the Republican climate denier is coming to an end. It’s a dying breed. I could name a handful of serious climate deniers still.”
The bad news: “Don’t get me wrong. There’s plenty of guys who talk about climate change but have no intention of ever doing anything or advancing clean energy or tax credits.” He described a conversation he had with House Minority Whip Steve Scalise (R-La.), who told him, “‘Basically our guys are comfortable talking about airplanes and cow farts’” to mock the Green New Deal, a proposed resolution by Rep. Alexandria Ocasio-Cortez (D-N.Y.). Scalise’s reference came from a draft FAQ accidentally released by Ocasio-Cortez’s staff and later retracted, which Republicans have seized on to claim Democrats secretly want to ban air travel and hamburgers.
Audap said Scalise continued to say that “‘we’re going to ring all the political hay out of the Green New Deal and then get around to doing some serious policy.’”
The Economy, Stupid
The key then, panelists said, is to focus on the economic benefits of solar rather than the environmental ones.
Boyd Brown, one of the three partners in lobbying firm Tompkins, Thompson & Brown, described his firm’s successful efforts earlier this year to get South Carolina’s Energy Freedom Act passed into law. Both houses of the state legislature unanimously voted to pass the bill after its introduction in January, and Gov. Henry McMaster signed it into law in May. Among the provisions supporting solar power, the law permanently eliminated any caps on net metering. It also requires utilities to consider offering neighborhood community solar programs and for their integrated resource plans to fairly evaluate solar-plus-storage investments.
Brown, a former Democratic member of the South Carolina House of Representatives, laid out the challenge the solar industry faces on the lobbying battlefield. “You got to start peeling back this onion legislatively in these states where utilities have had the ability to run roughshod over the landscape over the last half-century,” he said. “You guys are really new to the game. And these folks are entrenched.” During the battle for the Energy Freedom Act, “I think there were like eight registered solar lobbyists in South Carolina, versus 67 utility lobbyists. So it was really a David-versus-Goliath match.”
South Carolina is also a rural, deeply conservative state, and concerns about climate change do not resonate with its residents, nor with those in similar states, multiple speakers said.
But the bill was spurred by and benefited from “a groundswell of pure hatred, really, for Big Nuclear and Big Energy” after the failure of SCANA’s expansion of the V.C. Summer nuclear plant, for which customers were left on the hook, Brown said.
“I’m not sure the words ‘climate change’ ever came out of my mouth when I was lobbying legislators in South Carolina. We talked about ‘energy freedom’; we talked about consumer choices; we talked about free-market and fair-market principles,” he said. “We were like, ‘Where are … the free markets that Republicans are supposed to believe in?’ So we were really able to … build a coalition around Democrats who believed in protecting the environment and Republicans who believed in fair-market principles.”
Corey Schrodt, legislative director for Rep. Francis Rooney (R-Fla.), advised attendees to “always localize” data they use in their messages, such as how much money constituents would save or how many jobs would be created. “When people see the numbers, especially big jumps in numbers, it catches their attention.”
He also stressed that every call, email and letter from constituents to their representatives is logged by staff. Each week, members of Congress are given statistics on how many messages they received and what issues they were about. “When you call in, it does get tracked. I can’t speak for every office, but I know that most offices use that information to their advantage in how they contact, how they message their own constituents.”
“Just put your best foot forward,” Audap said. “Don’t feel like you need to convince them on climate change to get their support for solar. That’s frankly irrelevant in a lot of offices, even some Democratic offices.”
Brandon Presley, Mississippi Public Service Commissioner and new president of the National Association of Regulatory Utility Commissioners, said for many residents, it’s not a matter of whether they believe in climate change. As an elected official in a poor district, “I represent people that worry about tonight how they’re going to feed their children, and how they’re going to put gas in the van to get them back and forth to school. And if I’m talking to them about climate change, although that’s important to me … [I’m] not making headway” with his constituents on solar policy.
Next Steps
The Court of International Trade on Thursday blocked the Office of the U.S. Trade Representative’s decision to revoke bifacial modules’ exemption from the solar panel tariffs, ruling that the office had violated the Administrative Procedure Act by not providing notice or opportunity to comment on a proposed decision.
“This is an important temporary reprieve for the bifacial module exclusion,” Hopper said in a statement after the decision. “We will continue to make the case that the … tariffs are harming the U.S. industry and the American consumer and that the bifacial exclusion was a fair and reasonable solution to the problem of domestic module supply shortages.”
The International Trade Commission will submit a report to President Trump on the tariffs as part of its midterm review by Feb. 7. At Wednesday’s summit, SEIA General Counsel John Smirnow said he thinks that the administration would eventually drop the tariffs, but he noted that Trump is notoriously unpredictable, especially when it comes to trade. The president’s tweets can lead to a drop in the stock market one day, and a rebound the next. “Anybody who tells you they know what is happening, what’s going to happen, dates certain … I’d be surprised if they actually do,” he said.
Erin Duncan, SEIA vice president of congressional affairs, asked Schrodt if a carbon tax or dividend would be the next big policy battle after the tax credit extension. Rooney is the only Republican supporter of the Energy Innovation and Carbon Dividend Act, which would tax the carbon emitted by fuels, deposit the revenue into a new Carbon Dividend Trust Fund and distribute the funds back to taxpayers.
“The unfortunate reality is that we’re headed into a campaign year,” Schrodt said. “I’ve been on the Hill long enough to know that we have from now to maybe until March to really do anything. It’s going to take smaller bites of the apple.”
Unmentioned by Schrodt is that Rooney is not running for re-election. His announcement came in October, one day after he told CNN he was open to investigating whether Trump should be impeached.
In his Nov. 21 response, van Welie noted the region’s efforts to integrate energy efficiency and demand response into the wholesale markets and addressed the senators’ concern that the Energy Security Improvement (ESI) market design project “further delays market reforms that recognize and facilitate state public policies to grow clean energy and address climate change.”
Van Welie said that although the ESI would benefit generators with stored fossil fuel, it could also provide opportunities for solar facilities with battery storage “or an offshore wind farm that operates at a high capacity factor during winter.”
“Rather than delaying the transition to a renewable future, ESI may actually accelerate the transition to reliable, zero-carbon renewable resources and storage technologies by recognizing and compensating these resources for the reliability attributes they provide,” van Welie wrote.
Price-responsive demand (PRD) energy market activity by month | ISO-NE
PC Chair Nancy Chafetz cut short the ensuing discussion, assuring stakeholders that they would have ample opportunity to voice their opinions at NEPOOL Technical Committee meetings over the coming months.
The PC also received a briefing from ISO-NE Director Brook Colangelo on the RTO’s cybersecurity work and its participation in last month’s GridEx V exercise. (See GridEx V Throws New Tech Curveball.)
COO Vamsi Chadalavada apologized for a computer glitch on Nov. 3 that caused the submission window for external transactions to close at 9 a.m. instead of 10 a.m.
The problem was due to a software error related to the daylight saving time transition, he said.
A new eMarket application had been placed in service Oct. 23, and a few participants could not enter or modify external transactions after 9 a.m. on Nov. 3, though the application performed as expected for all other supply offers and demand bids.
The day-ahead market was cleared with the offers and bids as of 10 a.m., per normal schedule, and the issue was fixed by early afternoon, Chadalavada said.
One stakeholder suggested that the RTO have extra staff on hand when transitioning to new software, just in case customers need service.
Natural Gas Prices Double from October
Chadalavada reported the energy market value for last month was $284 million, through Nov. 25, up $82 million from October 2019 and down $319 million from the same month a year ago.
Natural gas prices doubled from October to November, helping push average real-time hub LMPs to $35.52/MWh, up 74% from the prior month.
However, natural gas prices and LMPs were down 46% and 36%, respectively, from November 2018.
Average day-ahead cleared physical energy during the peak hours as a percentage of forecasted load was 99.6% during November, up from 98.8% during October, with the minimum value for the month of 95.7% posted on Nov. 8.
Daily uplift, or net commitment period compensation (NCPC) payments, in November totaled $3.3 million through the 25th, up $600,000 from October and down $1.3 million from the same month last year.
NCPC payments over the period were 1.2% of the energy market value.
Committee Officers Elected, Appointed
The Participants Committee re-elected Chafetz (Customized Energy Solutions); Vice Chairs Calvin Bowie (Eversource Energy), David Cavanaugh (Energy New England), Douglas Hurley (Synapse Energy Economics) and Tom Kaslow (FirstLight Power Resources); Secretary David Doot (Day Pitney); and Assistant Secretary Sebastian Lombardi (Day Pitney). In addition, Michael Macrae, energy analytics manager for Harvard Dedicated Energy, was elected vice chair representing End Users. He replaces Liz Delaney, who stepped down after leaving the Environmental Defense Fund to become director of wholesale market development for Borrego Solar.
ISO-NE appointed Mariah Winkler to serve as the new chair of the NEPOOL Markets Committee. Winkler has 10 years of experience in the Forward Capacity Market and led the Reliability and Transmission committees through discussions on issues such as FCM fuel security reliability reviews and competitive transmission solicitations.
The RTO appointed Emily Laine to replace Winkler as the new chair of the Reliability and Transmission committees. Laine also serves as secretary of the Demand Resources Working Group.
After 17 years serving the MC, most recently as chair, Alex Kuznecow will now serve as chair of the NEPOOL Working Groups.
2020 Budget
The PC unanimously approved a 2020 budget of $6,365,000 for NEPOOL, up $90,000 (1.4%) from 2019’s spending plan. NEPOOL expects to spend $6,625,000 by the end of this year, $350,000 above the approved budget. Most of the increase stems from $340,000 in above-budget spending for Day Pitney’s counsel fees, an 8.6% exceedance. Independent financial adviser fees and disbursements were $5,000 over budget (12.5%), and committee meeting fees were $30,000 more than planned (4.4%). They were partially offset by $25,000 in savings on the Generation Information System (-2.9%).
Breakdown of projected 2020 NEPOOL expenses | NEPOOL
Consent Agenda
The PC unanimously approved the Reliability Committee’s recommendation to revise ISO-NE Operating Procedure No. 2 to incorporate a new reference document and clarify the RTO’s role in approving the scheduling of planned equipment maintenance and outages.
It also approved the Markets Committee’s recommendation to change Market Rule 1 to sunset the fuel security reliability review provisions following Forward Capacity Auction 14, one year earlier than currently planned. The RTO said the review will not be necessary for FCA 15, when the ESI design is expected to be in place.
That compliance filing is due Jan. 21. Requests for rehearing of FERC’s order are due by Dec. 23.
Doot also mentioned the commission’s Notice of Inquiry in March for comments on whether it should change its method of calculating returns on equity for electric transmission and natural gas and oil pipelines (PL19-4). The proceeding has produced splits between transmission owners and load interests, as well as calls for new policies to increase the efficiency of existing lines and mandates on interregional planning. (See Tx Incentives NOI Brings Calls for Broader Reforms.)
He also drew attention to the D.C. Circuit Court of Appeals’ ruling Thursday indicating it will reconsider its precedent that allows FERC to issue “tolling” orders to indefinitely delay action on requests for rehearing. (See related story, DC Circuit to Reconsider FERC Tolling Orders.)
