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December 19, 2025

SPP Regional State Committee Briefs: Oct. 28, 2019

LITTLE ROCK, Ark. — SPP’s Regional State Committee last week unanimously endorsed the elimination of revenue credits for sponsored transmission upgrades and the 2019 10-year transmission planning assessment.

Regulators asked to hear from renewable energy stakeholders, who participated in the Markets and Operations Policy Committee discussion of the Tariff revision earlier in October. The MOPC unanimously approved the change, which replaces Attachment Z2 credits for sponsored upgrades with incremental long-term congestion rights (ILTCRs), effective February 2020. (See “Stakeholders Endorse Eliminating Z2 Revenue Credits,” SPP MOPC Briefs: Oct. 15-16, 2019.)

EDP Renewables’ David Mindham repeated the industry’s position that the revision doesn’t comply with FERC’s policies on interconnections (Order 2003) and long-term firm transmission rights (Order 681).

“We don’t oppose removing Z2 credits,” he said. “We don’t feel there’s enough value in ILTCRs to be complying with FERC Order 2003.”

“I do agree there are some things that need to be fixed,” South Dakota Public Utilities Commissioner Kristie Fiegen said. “But I believe MOPC’s action is appropriate. I believe Z2 credits need to eliminated sooner rather than later.”

SPP General Counsel Paul Suskie argued that Z2 credits are not required by FERC policy and are instead a “self-imposed requirement” implemented through the stakeholder process.

“If an entity thought our ILTCRs do not comply with FERC, we would not appeal to FERC,” he said.

The RSC also signed off on SPP’s Integrated Transmission Planning 10-year assessment, a portfolio of 44 transmission projects with a total engineering and construction cost of $336 million. The 2019 ITP, the first after stakeholders revised the planning process, includes 166 miles of new extra-high-voltage transmission and 28 miles of rebuilt high-voltage infrastructure.

“We hope to solve both reliability and economic needs in a way that optimizes performance,” Senior Vice President of Engineering Lanny Nickell said. He said the portfolio is expected to lower congestion costs by more than 63 cents/MWh, a 21% reduction.

Nickell said he expects two of 345-kV projects, a 60-mile line in Oklahoma and a 105-mile line in Kansas, to become competitively bid. The projects have engineering and construction costs of $85.9 million and $162.6 million, respectively.

Louisiana’s Campbell: SPP Spending ‘Extravagant’

In a rare appearance before the RSC, Louisiana Public Service Commissioner Foster Campbell laid into SPP for what he termed “extravagant” spending on corporate facilities and executive salaries.

SPP
Louisiana PSC Commissioner Foster Campbell confers with staff following his comments. | © RTO Insider

Campbell, a self-described politician whose colorful career includes 26 years in the Louisiana State Senate and multiple failed bids for Congress and the governor’s office, was elected to the PSC in 2002. He normally gives his RSC proxy to PSC legal staffer Dana Shelton. That Campbell is up for election in 2020 led many onlookers to call his comments “political.”

“I’m not trying to be blunt, but telling it like it is,” he said. “The first time I came here, I never saw a building like that. I’ve been to a lot of places: capitols, the White House, fancy hotels … this building costs $67 million. That goes to my customers. I represent my customers, all in North Louisiana, and we have a lot of poor people.”

SPP CEO Nick Brown listened stoically as Campbell criticized him for a salary he said was $950,000. According to the RTO’s 2016 IRS Form 990, the last available through nonprofit tracker GuideStar, Brown’s total compensation was $1.2 million. By comparison, MISO’s 2017 990 lists CEO John Bear’s total compensation at $2.8 million.

“I know the good you’re doing. I hope you realize there are lots of poor folks out there, and I represent a lot of them,” Campbell said. “I would not want my people I represent to know we spend money like this. It’s too much.”

SPP Chairman Larry Altenbaumer cut Campbell off, saying Brown’s salary was commensurate with others in the industry and extolling the work of the Value and Affordability Task Force he chaired. (See SPP Value Group Finds No Silver Bullets.)

“I spent an entire year, with stakeholder involvement, looking at value and affordability of the organization with respect to our costs and the value delivered,” Altenbaumer said. “I feel very good about the comments we received.”

SPP
CEO Nick Brown listens to Campbell. | © RTO Insider

“I’m sure our architects would be amused that you think that this building is lavishly furnished,” Brown said, describing the building’s use of reclaimed materials and poured concrete for the floors. “Our Finance Committee, that consists predominantly of member companies, oversaw every specific of this building. This building is significantly cheaper than the leased space we were in over multiple locations in the area. To say we’re lavish with our money is simply not true.”

SPP clarified that Campbell’s $67 million figure applies to the value of its infrastructure assets, which includes the $52 million in construction costs for the Corporate Center’s four-story office building, modern operations data center and parking deck, and the backup ops center in nearby Maumelle. The operations center costs include required measures such as storm hardening, backup generation and fuel sources to ensure continued operations, the RTO said.

The RSC took a break after the exchange between Campbell, Brown and Altenbaumer. When the meeting resumed, Shelton was sitting in Campbell’s seat.

The Louisiana PSC is expected to vote on new RTO assignments in January.

Nebraska’s Grennan Elected as RSC President

Regulators approved the slate of officers for the committee’s leadership in 2020, with the Nebraska Power Review Board’s Dennis Grennan succeeding Arkansas Public Service Commissioner Kim O’Guinn as president.

South Dakota’s Fiegen will replace Grennan as vice president, while North Dakota Public Service Commissioner Randy Christmann will replace Fiegen as the RSC’s secretary.

SPP
Incoming RSC President Dennis Grennan, of Nebraska, and Iowa’s Geri Huber | © RTO Insider

“We have a lot on our plate for the next few months,” Grennan said. “We’ll be working on all of those items.”

O’Guinn in October was appointed to the National Association of Regulatory Utility Commissioners’ board of directors.

Arkansas’ Thomas to Lead OMS Half of Seams Group

Arkansas PSC Chairman Ted Thomas will replace Missouri Public Service Commissioner Daniel Hall as the Organization of MISO States lead on the RSC-OMS committee working to resolve seams issues between the two grid operators. (See OMS Panel Debates Merits of MISO-SPP Seams Projects.)

Missouri PSC economist Adam McKinnie told the RSC that Hall is leaving the commission when his term expires this month.

The committee will meet in an open session on Nov. 17 during NARUC’s annual meeting and education conference in San Antonio. Registration will be available through the OMS website.

— Tom Kleckner

NYISO Management Committee Briefs: Oct. 30, 2019

NYISO CEO Rich Dewey told the Management Committee that the ISO will delay deployment of a new energy management system (EMS) and business management system (BMS), missing the Oct. 31 deadline rather than risk any reliability problems.

As reported to the committee in September, the last day of October was the latest the ISO could cut over to the new system and still issue a necessary System and Organization Controls report to stakeholders by the Jan. 15, 2020, deadline. (See “Parallel Testing of EMS/BMS,” NYISO Management Committee Briefs: Sept. 25, 2019.)

“We encountered a number of problems related to both stability and synchronization of data,” Dewey said. “We made the decision not to deploy the new software, but to deploy it as soon as possible in the new year. We’re extremely disappointed in missing this deadline but don’t doubt we made the right decision in order to have a fully reliable system.”

Chief Information Officer Doug Chapman reported at the last MC meeting that March 1, 2020, is the next available deployment date.

Dewey said NYISO will work aggressively to correct the remaining known issues, complete the integrated testing and position the system to deploy as early as possible in 2020. Among other factors in deciding the new target is the need to maintain schedule flexibility to avoid deploying the new system in the middle of a cold snap when the electric system is under stress.

Howard Fromer, director of market policy for PSEG Power New York, asked how, with a three-year project, it was possible to learn at the “11th hour” that the new system doesn’t work.

“We break the system functionality into chunks, and only after it passes those tests do we piece it all together as a complete system with the real telemetry and real-time data inputs,” Dewey said. He explained that some of the more recent issues could only be discovered while the more complicated scenarios were performed by the operations team.

The control center has had double shifts for the past few weeks, running both old and new systems side by side, and while the ISO is “satisfied with the standalone applications … we decided we were better off taking a little extra time with their integration,” Dewey said.

Public Policy Tx Cost Caps OK’d

The MC voted to recommend that the Board of Directors approve a plan to allow developers to put voluntary cost caps in their proposals for projects falling under the ISO’s public policy transmission planning process.

NYISO Senior Manager for Transmission Planning Yachi Lin presented the proposal as approved by the Business Issues Committee earlier in October with 98.91% in favor. It passed the MC with 100% in favor with abstentions. (See NYISO Business Issues Committee Briefs: Oct. 16, 2019.)

Contingent on the board approving the measure at its November meeting, the ISO is prepared to make a Federal Power Act Section 205 filing with FERC in December for revisions to sections 6.10, 31.1, 31.4, and 31.7 of the Tariff. The changes would provide developers of projects selected to meet public policy needs the opportunity to make binding commitments to limit the amount of the capital costs of their projects. The commitments would be enforced through the tariffs and development agreements that NYISO enters into with each developer. Certain categories of unpredictable capital costs, such as unforeseeable environmental contamination, would be excluded from the cost cap, or cost recovery would be allowed if an excusing condition occurs, such as delays caused by interconnecting transmission owners.

“The principle we are establishing in the Tariff is if there are actions truly beyond the control of the developer, they should be excused from the cap,” Assistant General Counsel Carl Patka said.

Asked about a hypothetical case where the developer’s partner is responsible for actions or inactions that lead to exemption from the cost cap, Patka said, “That would be a fact-specific inquiry that would have to be evaluated on a case-by-case basis.”

Couch White attorney Amanda De Vito Trinsey, representing New York City, said that the city still continues to have concerns with the consumer protections but was withdrawing its opposition to the motion and abstaining from the vote, based on NYISO’s promise to police developer commitments and its Tariff to ensure that cost containment was being carried out as intended.

As at the BIC, Jane Quin, vice president of energy policy and regulatory affairs for Consolidated Edison, said her company and its Orange and Rockland Utilities subsidiary supported the concept but would also be abstaining because of concerns over changes to the evaluation process, which needs to include provisions for a TO to upgrade its own facilities.

Yes to Enhanced Credit Requirements

The MC also voted to recommend that the board approve changes to enhance credit reporting requirements and remedies.

Sheri Prevratil, manager of corporate credit, presented the proposal, including Tariff revisions that would require FERC approval, as she did earlier in the month when the BIC approved the changes.

NYISO proposed the changes after certain market participants last year defaulted on their payment or credit obligations. Some of those parties filed for Chapter 11 bankruptcy, while others were expelled from the ISO.

If the board approves the changes at its November meeting, NYISO will file Tariff revisions with FERC in November, Prevratil said.

The proposed Tariff changes add appropriate experience and resources to satisfy obligations to the ISO as minimum participation criteria. They also clarify that investigations that could have a material impact on the customer’s financial condition need to be reported to NYISO, if legally permitted, and add an obligation for a customer to take reasonable measures to obtain permission to disclose information on nonpublic investigations when possible.

A new provision allows NYISO to reject a new applicant determined to be an unreasonable credit risk based on a credit questionnaire and other review.

Survey Says: ISO Customers Happy

An annual customer satisfaction survey conducted by the Siena College Research Institute (SCRI) shows the ISO’s performance continuously increasing over the past four years.

SCRI Director Don Levy said a combined customer satisfaction and performance assessment score of 85.5% was the highest in four years, and that an executive approval score of 76% was better than it sounds, in that all respondents grade the ISO at better than “very good” in customer service.

Opportunities for improvement include conducting comprehensive long-term planning for the electric power system, advancing technological infrastructure and providing factual information to policymakers, stakeholders and investors.

NYISO
An annual customer satisfaction survey conducted by the Siena College Research Institute shows the ISO’s performance continuously increasing over the previous four years. | NYISO/SCRI

2020 NYISO Budget

The MC approved a flat budget of $168 million for next year, which the board will consider at its Nov. 19 meeting.

Budget and Priorities Working Group Chair Alan Ackerman, of Customized Energy Solutions, presented the final budget proposal to the committee.

The working group made slight changes since he provided an overview last month, reflecting the delay in deploying the new EMS/BMS system, but the bottom line remains unchanged at $168 million allocated across a forecast of 154.3 million MWh.

The budget calls for a Rate Schedule 1 charge of $1.089/MWh. Comparatively, this year’s budget was $168.2 million allocated across 157.1 million MWh for a Rate Schedule 1 charge of $1.071/MWh.

Couch White attorney Michael Mager, who represents Multiple Intervenors, a coalition of large industrial, commercial and institutional energy customers, commended the ISO for working hard to deliver a conservative budget with no increase.

Breidenbaugh Elected New Vice Chair

Stakeholders elected Aaron Breidenbaugh of Luthin Associates as vice chair of the committee for 2020.

Breidenbaugh, whose firm also represents an unincorporated group of nonprofit institutional customers known as Consumer Power Advocates, has been serving as BIC chair this year.

— Michael Kuser

PG&E Could Still Reject PPAs, Analysts Say

By Hudson Sangree

SACRAMENTO, Calif. — A panel of analysts at a renewable energy conference warned that Pacific Gas and Electric could still reject its renewable energy power purchase agreements in bankruptcy despite assurances that it will honor those contracts.

“They may be rejected. They may not. It’s very difficult for us to tell,” Terry Pratt, energy and industrials director with Fitch Ratings, told the audience at Infocast’s CA Renewable Procurement Summit 2.0.

PG&E’s equipment has come under suspicion for starting the Kincade Fire on Oct. 23, and the utility intentionally blacked out more than 2 million residents twice in recent weeks as part of its public safety power shutoff (PSPS) program. The company’s stock sank briefly to a record low of less than $4/share on Monday. (See PG&E Stock Plummets amid Wildfires.)

PG&E PPAs
Infocast’s CA Renewable Energy Procurement Summit 2.0 took place at the new Kimpton Sawyer Hotel in downtown Sacramento, next to the city’s new basketball arena. | © RTO Insider

Those factors only add uncertainty to what PG&E might do during its Chapter 11 reorganization in the U.S. Bankruptcy Court in San Francisco, analysts said. The company filed for bankruptcy protection in January following two years of devastating wildfires.

“Any [renewable energy] project that has a PG&E offtake is not getting paid when PG&E turns the electricity off,” Pratt said.

Helen Kou, decentralized energy analyst with Bloomberg NEF, said clients ask the research firm whether PG&E can or should renege on its PPAs, many of which were signed when wind and solar power cost far more than today’s market prices. Experts interviewed by Bloomberg, she said, have differing opinions.

PG&E PPAs
In a panel moderated by V. John White of CEERT, far left, financial analysts (left to right) Anne Selting, S&P Global; Helen Kou, Bloomberg NEF; and Terry Pratt, Fitch Ratings, discussed the impact of PG&E’s bankruptcy on renewable energy contracts. | © RTO Insider

One audience member asked why it would benefit PG&E to reject above-market-rate PPAs, as PG&E passes on the cost of those contracts to ratepayers.

Anne Selting, analytical manager with S&P Global Infrastructure Ratings, said the company will likely have to layer on wildfire costs to its electricity rates post-bankruptcy, and it can only increase its rates so much before the situation becomes unworkable. Trimming its PPA costs would help the utility going forward, she said.

The possibility that PG&E could reject its contracts for renewable energy or stop paying has put projects at risk that primarily serve the utility, Selting said.

Projects are typically heavily leveraged with debt, she explained. Lenders will often provide loans up to a 90% loan-to-project-value ratio with the understanding that dependable payments from utilities such as PG&E will make sure debt gets serviced, she said.

With PG&E in bankruptcy, and facing new threats to its solvency, there’s less assurance that it will honor its contracts, Selting said.

That’s why Topaz Solar Farm, one of the nation’s largest solar projects, saw its credit rating tumble after PG&E filed for bankruptcy, even though the utility hasn’t missed any payments to Topaz, she said. The solar array in San Luis Obispo County is owned by Berkshire Hathaway Energy. PG&E is the sole offtaker of Topaz’s solar production.

PG&E PPAs
V. John White, executive director of the Center for Energy Efficiency and Renewable Technologies (CEERT) in Sacramento moderated a panel on the impact of PG&E’s bankruptcy on renewable energy contracts. | © RTO Insider

In comparison to today’s wildfire crisis, the Western Energy Crisis of 2000-2001 was relatively straightforward, Selting said. Then, Enron and others took advantage of flaws in California’s electricity deregulation scheme, but policymakers soon figured out long-term fixes.

In contrast, PG&E’s new chairman, Bill Johnson, said at a press conference earlier this month that PSPS could continue for a decade as the utility hardens its grid. That’s quite different and far more uncertain, Selting said. (See PG&E Says Blackouts Will Continue.)

“We have very little control over where we’re heading,” she said. “The ability to respond quickly and fix the problem doesn’t exist.

“We really are at a moment, where I think, at least for California, the risks are being recalibrated,” Selting said. “And I don’t think anyone in this room knows what that means.”

Minnesota Utilities Reunite for CapX2050 Study

The team behind the CapX2020 transmission study is reuniting again for an effort that looks ahead to 2050. But this time around, the Minnesota utilities grouped behind the project will focus on decarbonization goals rather than reliability needs.

Furthermore, the CapX2050 Transmission Vision study will look beyond transmission for possible solutions, the companies say.

Spearheaded by Great River Energy and Xcel Energy, the new effort will rely on the combined internal resources of 10 Minnesota utilities, said Great River Energy Director of Transmission Planning Gordon Pietsch, the study’s co-lead.

“What we’re doing is trying to address impacts on Minnesota and the region going carbon-free,” Pietsch said in an interview with RTO Insider.

“Like the Blues Brothers, [we] are on a mission to put the band back together again, and we are working with the original CapX2020 utilities that built over $2 billion of transmission projects in the Upper Midwest over the last 10 years,” Xcel Energy CEO Ben Fowke told analysts during an Oct. 24 third-quarter earnings call. (See Xcel Talks Tx Build After Earnings Come up Short.)

CapX2020
CapX2020 construction | CapX2020

While CapX2020 was driven by local and regional reliability needs and renewable portfolios standards, the new study will focus on generation retirements, renewable additions, inverter-based issues and any foreseen reliability and stability impacts resulting from the growing dominance of renewables. As Fowke noted, CapX2020 culminated in an 800-mile, grid expansion in the Upper Midwest, including four 345-kV transmission lines in Minnesota, North Dakota, South Dakota and Wisconsin and a 230-kV transmission line in northern Minnesota.

If the study’s objective seems vague, that’s the point, Great River Energy executives said. There’s not a definitive timeline, any potential project ideas or specific geographic areas of focus. The utilities stress that they’re not foreclosing any potential solutions, which aren’t limited to transmission projects.

Great River Energy Chief Transmission Officer Priti Patel said that while she couldn’t definitively say how long the study might take, now is the time to “begin the discussion around operating challenges that might arise as we move to a decarbonized future.”

Over time, she said, project needs will come into focus.

Pietsch said the study could yield not only transmission projects but needs that other technologies can address.

“We don’t know what those technologies will be yet, but the system that we operate today will be much different in a carbon-free future,” he said. “Transmission planning is imperative as utilities move to non-dispatchable generation.”

Pietsch said the study will “articulate the challenges we’ve seen on the system today and how they might be different in the future.” That work will include a look at grid needs under escalating weather events, he said. The study will also examine power flow, system stability, short-circuit current availability and other operating issues.

No Quick Fixes

The CapX2050 study will study Minnesota, eastern North Dakota, eastern South Dakota, western Wisconsin and the surrounding areas to identify potential constraints. Patel said the utilities will share their findings with regulators, lawmakers and the public. She said the utilities would also put results before MISO planners, if necessary.

“It may not come as a surprise that some of our issues might be indicated in the MISO study work as well,” Patel said, referencing the RTO’s ongoing renewable integration impact assessment.

“We want to say, ‘Here’s what we’ve learned about going carbon-free,’” Pietsch said.

CapX2020
CapX2020 transmission | CapX2020

Fowke said the need for new transmission is illustrated by NextEra Energy’s Crowned Ridge wind project in northeastern South Dakota having to be scaled back by 100 MW because of increased MISO interconnection upgrade costs. He said Xcel had planned to assume control of 100 MW from Crowned Ridge as a build-to-own transfer project. NextEra’s decision to reduce the capacity “highlights the need to expand transmission investment to address congestion and ensure the viability of future renewable projects,” he said.

“The work we did with CapX2020 opened up the door for a lot of renewables, but [the system] is starting … to get constrained. And I do think long-term, we are going to need more transmission development in the region to make sure we can continue to see renewables come into the MISO market,” Fowke said.

Xcel CFO Bob Frenzel cautioned that it’s still “early days” for the CapX2050 vision study.

“I don’t think this is a very quick process. I think this is going to take at least five years through planning before we start getting into real capital plans and construction time frames,” Frenzel said. “So I don’t want to suggest that something is going to change in the next year … in terms of congestion in the MISO region. And we are seeing similar stuff in SPP as well in terms of just congestion and queues being backed up and projects being assessed with significant upgrade costs.”

But it’s clear to the group that 2050 will be a watershed year for clean energy. Minnesota Gov. Tim Walz has called for 100% carbon-free electricity in the state by 2050. Xcel similarly has a plan to go carbon-free by then.

“I would say that we choose 2050 because that’s what we’ve heard,” Patel said.

CapX2050’s other participating utilities include Central Municipal Power Agency, Dairyland Power Cooperative, Minnesota Power, Missouri River Energy Services, Otter Tail Power, Rochester Public Utilities, Southern Minnesota Municipal Power Agency and WPPI Energy.

Exelon Pledges Reforms amid Grand Jury Probe

By Rich Heidorn Jr.

Exelon CEO Chris Crane said Thursday the utility is cooperating with a federal investigation into its lobbying of the Illinois legislature and will make changes to ensure the “highest possible” ethical standards in the future.

Exelon
Former Exelon Utilities CEO Anne Pramaggiore | © RTO Insider

The grand jury probe led to the retirement of Exelon Utilities CEO Anne Pramaggiore on Oct. 15, less than a week after the company disclosed it had received a subpoena seeking communications between Exelon and state Sen. Martin Sandoval, a Chicago Democrat whose home and offices were raided by FBI agents in September. Sandoval’s daughter was hired by Exelon’s Commonwealth Edison during Pramaggiore’s tenure.

The subpoena is part of a wide-ranging pay-for-play investigation, according to the Chicago Tribune. The Illinois Senate said it had been subpoenaed for “items related to ComEd, Exelon [and] any issue supported by any of those businesses … including, but not limited to, rate increases.”

The Tribune dates the ComEd lobbying investigation to at least mid-May, when the FBI searched the homes of former lobbyist Mike McClain, an ally of House Speaker Michael Madigan and former Chicago Alderman Michael R. Zalewski, seeking records about attempts to get ComEd lobbying work for Zalewski.

Public radio station WBEZ reported that federal officials are probing whether ComEd hired “multiple politically connected employees and consultants in exchange for favorable government actions.” Many did “little or no work,” and some had ties to Madigan, the station reported.

In May, the FBI raided the Chicago home of Alderman Marty Quinn’s brother, Kevin, a Madigan aide who was fired over sexual harassment allegations. The Tribune has reported that investigators are interested in $10,000 in payments that five current or former ComEd lobbyists made to Quinn after his firing.

Outside Investigation

Speaking during the company’s third-quarter earnings call Thursday, Crane said the company’s outside lawyers are conducting “an exhaustive investigation of the facts relevant to the subpoenas” and briefing a special committee of Exelon’s board, which is represented by its own outside counsel.

Exelon
Exelon CEO Chris Crane | © RTO Insider

“Exelon’s outside lawyers are sharing the results of the investigation with the government in an ongoing basis. Their investigation is enabling us to determine what changes are necessary internally to ensure that going forward, we operate at the highest possible standards — not whether actions have been legal or not, but rather which go beyond the ethical reproach,” Crane said in a halting prepared statement.

Crane said the company will “immediately take action” to correct any problems it learns of from the attorneys doing the investigation. “Cooperation with the government — full cooperation, very open cooperation — is the imperative here. We’re not passing judgment on [whether] anything [is] legal or illegal in some of our past practices with contract lobbyists or consultants.”

‘Eye on the Ball’

Although he acknowledged the investigation is dominating the news about Exelon and ComEd, he insisted executives were “keeping our eye on the ball by staying focused on the operational and strategic path that has delivered the [company’s] success.”

The company reported net income of $772 million ($0.79/share) for the quarter, an increase over the $733 million ($0.76/share) a year earlier. Non-GAAP operating earnings were also up slightly to $900 million ($0.92/share) versus $856 million ($0.88/share) in 2018.

But the disclosures appear to have shaken investors. Shares have dropped 8% since July 11, the day before the company disclosed it had received its first subpoena. After falling to a low of $44.40 on Aug. 1, prices rallied to $48.45 before sliding again after the company disclosed the second subpoena Oct. 4. Shares closed Thursday at $45.49, down $1.17 (-2.5%).

In its first disclosure, Exelon said it was asked to produce “information concerning [Exelon and ComEd’s] lobbying activities” in Illinois. The second subpoena sought “records of any communications with certain individuals and entities, including Illinois state Sen. Martin Sandoval,” the company disclosed.

In between the two disclosures, Fidel Marquez, senior vice president at ComEd in charge of government affairs, retired Oct. 2.

Nuke Plants at Risk

The investigation comes as Exelon is trying to persuade the Illinois legislature to prop up the finances of its four nuclear plants in the state that are not already receiving zero-emission credits.

Crane said the drafting of the legislation will be dependent on Glick Recusal May Mean No MOPR Ruling Before December.)

“I can’t stress how important this spring legislative session will be for the four sites not coved by ZECs,” Crane told analysts Thursday. “The first half of 2020 will be a real critical point in decision-making and potential retirement announcements. … If for some reason we don’t garner support … to go forward with the legislation [based on] what we see in the market forwards today, plants will start to shut down. That’s the reality. … Without being able to get capacity revenue for those eight reactors, and the market forwards being as low as they are right now, it’s uneconomic. And the one thing we’re not going to do is sit around and damage the balance sheet.”

Former Heir Apparent

Pramaggiore began working for Exelon in 2006, when she joined ComEd as an attorney. She was named CEO of the utility in 2012 and promoted to oversee all of Exelon’s six utilities in May 2018, making her a leading candidate to succeed Crane.

Exelon
Interim Exelon Utilities CEO Calvin G. Butler Jr. | © RTO Insider

She was credited with helping ComEd win several legislative initiatives, including a 2011 law that authorized $2.6 billion in grid-modernization investments over a decade. The company’s delivery rates reportedly jumped 37% from 2013 to 2019 under the law. Exelon and ComEd have one of the biggest lobbying forces in Springfield. Pramaggiore reportedly donated more than $240,000 to Illinois politicians since 2005.

In addition to retiring from Exelon, Pramaggiore resigned as chair of the Federal Reserve Bank of Chicago. Calvin G. Butler Jr., the CEO of Baltimore Gas and Electric, replaced her as interim CEO of Exelon Utilities.

[Editor’s Note: An earlier version of this story incorrectly stated that Pramaggiore had resigned as a member of the DePaul University board of trustees.]

Western EIM Benefits Top $800 Million

By Hudson Sangree

FOLSOM, Calif. — CAISO’s Western Energy Imbalance Market posted more than $801 million in benefits for its participants after five years of reporting quarterly results, the EIM’s Governing Body members heard Wednesday.

Western EIM

CAISO Vice President Mark Rothleder briefed Governing Body members on the EIM’s third-quarter performance. | © RTO Insider

Mark Rothleder, the ISO’s vice president for market quality and California regulatory affairs, told the Governing Body’s four current members (one seat is vacant) that the EIM racked up $64 million in benefits in the third quarter of 2019 — its 20th quarterly report.

“It marks a five-year mark in terms of operation of the EIM,” Rothleder said.

Arizona Public Service received the bulk of the third-quarter benefits, with more than $20 million in savings, followed by PacifiCorp and Portland General Electric, which each benefited by about $9.5 million, according to the ISO.

The benefits were less than the $100 million posted during the third quarter of 2018 because natural gas price spikes last year created additional benefits for EIM participants, Rothleder said.

The real-time EIM uses security-constrained economic dispatch technology to find and deliver low-cost electricity across eight Western states and facilitates the use of renewable energy that might otherwise be curtailed.

With new members steadily joining, the EIM is on track by 2022 to have members representing more 77% of load in the Western Interconnection, Rothleder said.

Its nascent competitor, SPP’s Western Energy Imbalance Service, started up in June and announced its first three members Sept. 9. (See WAPA, Basin, Tri-State Sign up with SPP EIS.)

The EIM’s nine current members include Idaho Power, NV Energy, Powerex, Puget Sound Energy and Sacramento Municipal Utility District. Those scheduled to join include Arizona’s Salt River Project and Seattle City Light in 2020, the Los Angeles Department of Water and Power and Public Service Company of New Mexico in 2021, and the Bonneville Power Administration in 2022.

“We’ve got a robust set of implementations coming up,” Rothleder told Governing Body members.

Western EIM Governing Body members

EIM Governing Body members (left to right) Anita Decker, John Prescott, Carl Linvill and Valerie Fong heard a report on the market’s benefits. | © RTO Insider

Regional Issue Forum Changes

At the EIM meeting Wednesday, Pam Sporborg, with Portland General Electric, made her first presentation, by phone, as the new chair of the EIM’s Regional Issues Forum.

Sporborg recently took over from Therese Hampton, executive director of the Pacific Northwest’s Public Generating Pool.

“She’s leaving quite big shoes to fill,” Sporborg said. “I’m looking forward to taking on the chair role and all the work to hold the RIF together.”

Jennifer Gardner, a senior attorney with Western Resource Advocates, has assumed the role of the RIF’s vice chair.

The RIF’s next meeting will be Dec. 3 in Las Vegas, where the EIM Governing Body is set to meet Dec. 4.

There will be updates from new EIM entrants such as Tucson Electric Power, a discussion of resource sufficiency versus resource adequacy, and perhaps a presentation from FERC on price formation, Sporborg said.

“We’re putting together quite an exciting agenda for that meeting,” she said.

Avangrid Earnings Revive on Wind, New Assets

By Michael Kuser

Increased wind output helped Avangrid’s profits jump 20% in the third quarter as the company continued to see strong growth in its renewables fleet.

The company earned $150 million ($0.48/share) during the quarter, compared with $125 million ($0.40/share) in 2018. Net income for the first nine months was flat at $477 million, compared with $476 million for the same period last year.

The results “reflect really positive performance in renewables that improved production due to better wind resource and new assets in service during the quarter,” CEO James P. Torgerson said in a call with analysts Wednesday.

A subsidiary of Spain-based Iberdrola, Avangrid owns United Illuminating, Connecticut Natural Gas, Central Maine Power, New York State Electric and Gas, and Rochester Gas & Electric, as well as generating assets throughout the U.S.

Avangrid

Avangrid expects its 1,200-MW New England Clean Energy Connect transmission project to start construction in the second quarter of 2020 and come online by the end of 2022. | Avangrid

Renewables Projects

Torgerson noted Avangrid’s Renewables division has commissioned 427 MW of onshore wind this year and has about 562 MW under construction. The company’s approximately 16.5-GW pipeline of renewable energy projects is about evenly divided among onshore wind, offshore wind and solar.

The company last quarter executed a new power purchase agreement with Oregon-based Portland General Electric for the repowering of the 75-MW Klondike II wind project.

Avangrid

Vineyard Wind’s leases south of Cape Cod could potentially host 5 GW of generation. | Avangrid

It also inked a $112 million deal with Axium, expected to close in the fourth quarter, to sell a 50% ownership interest in a wind farm and a solar project in Arizona, both of which have long-term PPAs. Torgerson characterized the deal as a continuing strategy to recycle capital and optimize pipeline projects and assets.

He also said the company expects the Bureau of Ocean Energy Management to issue a supplemental environmental impact statement for the Vineyard Wind offshore project “by late 2019, early 2020.” Avangrid is a 50/50 partner in the offshore venture with Copenhagen Infrastructure Partners.

Vineyard Wind submitted separate bids in the Massachusetts and Connecticut offshore wind solicitations but lost out to Mayflower Wind on Wednesday for Massachusetts’ second 800-MW offshore award. Connecticut is expected to announce its contract award in November.

On the transmission front, the company expects its $950 million, 1,200-MW New England Clean Energy Connect project to start construction in the second quarter of 2020 following receipt of the final permits from Maine and the U.S. Army Corps of Engineers, as well as approval from ISO-NE.

“The project is progressing well,” Torgerson said.

Utility Rates

NYSEG and RG&E in May filed one-year rate cases requesting new rates from the New York Public Service Commission.

Both utilities are seeking a 9.5% return on equity and proposing additional capital for resilience plans, which include an vegetation management and automated metering infrastructure, Torgerson said.

He said the company expects the rate cases to substantially mitigate impacts of outage restoration, staging costs and overtime, particularly for increased vegetation management at NYSEG, which was penalized by the PSC in June for performance issues. (See NYPSC Dings Utilities for 2018 Reliability, Safety.)

CMP has an ongoing rate case with a decision expected early in the first quarter of 2020. The utility has requested an ROE of 10%, above the current 9.45%, Torgerson said. The Maine Public Utilities Commission proposed lowering it to 8.75% because of customer service issues, he said. The company in turn recommended organizational changes and the establishment of a $6 million customer benefit fund, plus the establishment of an energy assessment pilot with Efficiency Maine.

Call transcript courtesy of Motley Fool.

Robb Sees Calmer 2020 After ‘Turbulent’ Year

By Rich Heidorn Jr.

NERC CEO Jim Robb told board members Thursday he’s “feeling very good about” his senior executives after what he acknowledged was a “turbulent year” for the management team.

“We’ve had a pretty turbulent year in terms of the makeup on that team, but … I keep reminding myself that every time a door closes, a window opens,” he told the Corporate Governance and Human Resources Committee on a conference call.

NERC Robb
NERC CEO Jim Robb | © ERO Insider

Since Robb joined NERC from the Western Electricity Coordinating Council in April 2018, the corporation has seen the retirement of General Counsel Charles Berardesco, and the departures of CFO and Chief Administrative Officer Scott Jones and Senior Vice President and Chief Security Officer Marcus Sachs. James Merlo, vice president and director of reliability risk management, abruptly left the company in September. (See Merlo Out at NERC.)

“We have spent a lot of time over the last quarter really getting the senior team into alignment around a whole bunch of priorities … and I think we really have a very sound, and most importantly, a very aligned, team of executives leading the company right now,” Robb told the committee.

He said it was “pretty astounding, given all the change we’re going through, that our attrition level is hovering below 10%. We obviously would like to drive that number down.”

“Some of that attrition is regretted,” he added. “Some not.”

Robb said a “steering committee” of officers working with Director of Human Resources Damon Epperson “on renewing our HR programs” is paying dividends.

“One, we’re getting more heads against some thorny issues of how to continue to modernize our approach to HR to be aligned with the transformational aspirations we have for the company [NERC] and [ERO] Enterprise,” he said. “The other thing that it’s doing is also taking away everybody’s ability to complain about HR, because we’re now all part of the problem.”

He said the team is considering changes to its recruiting and onboarding practices and is “going to be taking a hard look at our performance management approach.”

Diversity and Inclusion

“Most importantly, we’ve laid out a series of aspirations for ourselves both in terms of the workplace environment we want to create for our staff, but also the importance we want to place on diversity and inclusion — that, as we continue to evolve the organization, we’re making it more reflective of the society that we live in and serve.”

Robb’s approach won an endorsement from Director Kenneth W. DeFontes Jr.

“If you design [a company in which] HR is the HR organization’s responsibility — not line management — you won’t be successful,” he said. “It sounds like you’re off on the right track to engage your leadership team [into] accepting this responsibility.”

Vacancies Remaining

NERC’s 2020 business plan reduced Robb’s direct reports to five from eight, two of which — chief financial and administrative officer, and the general counsel — are the subject of an ongoing search. Robb said last week he expects to announce the new executives by the end of November.

Sonia Mendonca, Berardesco’s former deputy, is interim general counsel, and Controller Andy Sharp, who served under Jones, is interim CFO.

Janet Sena, senior vice president for policy and external affairs, and Mark Lauby, senior vice president and chief engineer, are the only direct reports to Robb who remain from the executive team under former CEO Gerry Cauley.

Robb’s other direct report, Bill Lawrence, chief security officer and director of the Electricity Information Sharing and Analysis Center, replaced Sachs in August 2018. Lawrence was mysteriously absent last week at GridSecCon, E-ISAC’s annual conference, which drew more than 600 people. (See related story, Overheard at GridSecCon 2019.)

Robb said Lawrence was “taking some time off” but expected him to return.

Design Basis Threat: ‘Best Security Training Ever’

By Rich Heidorn Jr.

ATLANTA — Peter Scalici, manager of security outreach programs for Northeast Power Coordinating Council, still speaks with the blunt, no-nonsense demeanor of the New York City police detective he once was.

Design Basis Threat
Peter Scalici, Northeast Power Coordinating Council | © ERO Insider

“I was never a fan of academia telling us how to handle real-world situations. I felt that many times we reached paralysis through analysis, where we were analyzing things so much that we never took action, we never solved the problem,” he said.

But when he learned about NERC’s Design Basis Threat (DBT) assessment, he was very impressed, he told NERC’s GridSecCon 2019 last week. “I said, ‘Now here’s something that really has value.’”

Based on a concept that originated in the nuclear power industry, NERC’s DBT was created in 2016 by the Physical Security Advisory Group. It is a tool for identifying the intentions and capabilities of potential adversaries and determining appropriate, cost-effective defensive measures.

Design Basis Threat
Sam Chanoski, E-ISAC | © ERO Insider

Sam Chanoski, director of intelligence for the Electricity Information Sharing and Analysis Center, noted that hackers’ motives can vary depending on who they are: nation states seeking to affect geopolitics; extortionists seeking financial gain; or nihilists that “might want to break something or set it on fire.”

“It really gets down to imagination bounded by the laws of physics,” he said.

Design Basis Threat
David Godfrey, Garland Power & Light | © ERO Insider

David Godfrey, critical infrastructure protection manager for Garland Power & Light, summed up the DBT this way: “What does winning look like for them? What does losing look like for us?

“It doesn’t always cost a lot to protect something, but it does take the knowledge of a good group of experienced folks,” Godfrey explained. “And that’s not just security folks. That is your substation people. That is engineers; your cyber folks; operations. Get them all in the room, and put their heads together.”

Scalici agreed, saying NPCC will integrate the DBT into the voluntary physical security assessments it offers its members. “This opens up everybody’s eyes to how everything is connected,” he said.

David Jarrett, Southern California Edison | © ERO Insider

David Jarrett, Southern California Edison’s senior adviser for physical security, said the tool can be used by anybody within a utility’s security organization with some training.

The E-ISAC offers workshops to utilities to help them implement the program, which focuses on the functions of “detection, delay and response” to baseline a physical protection system and determine cost-effective upgrades.

One key step is comparing the amount of time adversaries require in their attacks (task time) with the time the response force requires to engage or neutralize the attack (response time).

Ross Johnson, president of Bridgehead Security Consulting, talked about the need to update the DBT in the face of new technologies, such as the battery-powered Metabo 36-V angle grinder, which he said can cut through a chain link fence in about 30 seconds.

Ross Johnson, Bridgehead Security Consulting | © ERO Insider

Johnson noted that the ASTM International standards for fence penetrations for low- and moderate-threat facilities do not identify battery-operated tools as concerns because they were written when batteries were extremely heavy and not very powerful.

“They didn’t work very well so it wasn’t really an issue,” he said. “Today it’s different. Tools like this are affordable: That’s $450 at Home Depot. And it will go through anything very, very quickly.”

The ASTM standards are being updated accordingly, he said. “Which is really good news for us because what we don’t want to use is fencing that we think is good enough but doesn’t actually protect us against this particular tool.”

The other good news: New fencing can withstand such tools. “Sometimes, depending on the quality of the steel used in the fence, it’s so hard to cut that it wears the grinding wheel out or wears the battery out before it can get through,” Johnson said. “So that kind of fencing is your friend.”

Godfrey said the best fences can provide up to an hour of deterrence. “We have substations that take law enforcement an hour to get to,” he said.

War Games

Johnson said E-ISAC’s DBT implementation workshop is the best security training he’s ever had. “The first time I took it, by the end of the five days, I was embarrassed at the amount that I learned,” he said.

Design Basis Threat
Exhibitors at GridSecCon included vendors for razor wire and chain link fence. | © ERO Insider

Johnson said the DBT implementation “teaches you how to … take all of the various pieces of the physical protection system … and use them together in order to defeat an adversary.”

“In the old days, which weren’t that long ago, we would design these security facilities … put a fence up here, put cameras here … but we didn’t ever really war game it out against an adversary. We just hoped it worked. And it almost always does, because you actually rarely get attacked by determined adversaries. So, we’re never faced with our own failure.”

One thing to avoid, the speakers said, is having too many participants in a DBT workshop or participants who will dominate the discussions.

“If you get the right five or six people in the room you can solve a lot of scenarios,” Godfrey said.

“The best number is about 20,” said Michael Bowen, associate director of physical security for the E-ISAC.

Overheard at GridSecCon 2019

ATLANTA — NERC’s ninth annual GridSecCon was the biggest yet, as more than 600 attendees heard talks on drones, insider threats, supply chain risks and other topics. Here’s some of the highlights of the conference, which was organized by NERC’s Electricity Information Sharing and Analysis Center.

NERC GridSecCon
NERC’s ninth annual GridSecCon was the biggest yet, as more than 600 attendees heard talks on drones, insider threats, supply chain risks and other topics. | © ERO Insider

‘Prepared to be Overwhelmed?’

Brian Harrell, assistant director of the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency, rallied the attendees, saying critical infrastructure owners must understand their “gaps” to protect against nation-state attacks.

“It’s on the margins, on the folds; it’s where you’re not looking that an adversary … is looking to exploit,” he said. “We should all understand that one day, we will be faced with a security event. Something will happen in our system. Let me ask this very key question: Are you prepared to be overwhelmed, when it’s the fog of war; there’s incomplete information; everyone is yelling on the radio at the same exact time? Maybe there;s blood on the ground. Are we prepared to be overwhelmed?”

NERC GridSecCon
Brian M. Harrell, DHS | © ERO Insider

Although DHS has moved past the post-9/11 antiterrorism mission on which it was founded, it cannot prevent sabotage of industrial control systems by itself, Harrell said.

“It takes patriots. It takes those with a vested interest in how we leave this country to our children. So I ask as we leave this conference … that you leave with a ‘to-do’ list, with a list of items that we can do to prepare the next generation, promote resilience, protect our critical infrastructure and work for the common good of national security.”

Harrell said he is surprised at how far behind other critical infrastructure sectors are in their cybersecurity measures compared with the electric industry. DHS is urging other sectors to adopt the model of the Electricity Subsector Coordinating Council (ESCC), which includes more than 30 CEOs of investor-owned utilities, public power companies, rural electric cooperatives and industry trade groups.

Because it is led by CEOs, Harrell said, “when we have a robust conversation around the table, and we say, ‘This is the plan; let’s go forward; let’s make things happen,’ it actually happens. Instead, the other model [without CEOs] is, ‘Let me go back to the shop … get concurrence, get some approvals and then we’ll see you next quarter,’” Harrell continued. “That is ineffective. It is slow. It is burdensome.”

Harrell also discussed insider threats, saying, “I am convinced that we have individuals within our companies that have the institutional knowledge as to how to bring us to our knees. They understand the keys to the kingdom. They understand what the crown jewels are.”

Conducting background checks every seven years isn’t enough protection, he said. “Do we have the technology in place to understand what data is leaving our system and going to somebody else’s Gmail?” he asked.

Fanning: AI Key to Defense Against Increasing Threats

Southern Co. CEO Tom Fanning, co-chair of the ESCC, said the rise of machine learning has resulted in an explosion of attacks against utilities and a need for robust artificial intelligence. Fanning said utilities have faced millions of attacks daily, including efforts to position, probe defenses and gain intelligence.

NERC GridSecCon
Southern Co. CEO Tom Fanning | © ERO Insider

“Heretofore you can imagine a nondescript concrete building on the streets of Beijing, China, with armies of people banging keyboards trying to get in,” he said. “But as machines learn how to attack, we are now into trillions of [attacks] a day, and the success and failure of attack defense will be driven by how good your artificial intelligence is. It’s almost beyond human capability to … understand an attack and how to defend ourselves.”

Fanning said the Cyberspace Solarium Commission, a bipartisan group of members of Congress, former government officials and industry representatives authorized by Congress, will produce a report later this year or in early 2020 that will “reimagine how government and private industry work together” to address cyber threats.

“The concept of [information] sharing will be obviated in the not-too-distant future. Sharing is too slow,” he said. “I think we will consider an effort to join the data-sharing, knowledge-sharing and sharing of insight among and between the intelligence community, the defense community and private industry in a way that we have never seen before.”

Collaborating to Deal with Squirrels and Nation-states

Karen S. Evans, assistant secretary in the Department of Energy’s Office of Cybersecurity, Energy Security and Emergency Response, joked that her responsibilities span from “squirrels to nation-states.”

NERC GridSecCon
Karen S. Evans, DOE | © ERO Insider

“My leadership’s greatest fear is when we are responding to a natural disaster, that that is when our country is most vulnerable. And that’s when we would be taken advantage of,” she said.

Zach Tudor, Idaho National Laboratory | © ERO Insider

She said the relationships between industry, DOE and its national laboratories are crucial to protecting the grid. “The only reason why this is going to work is because of the partnerships that we have within the sector,” she said.

Zach Tudor, Idaho National Laboratory’s associate director for national and homeland security, had a similar message. “The reason we can speak with one voice is you’ve built a community of trust,” he told the audience.

Ross Johnson, president of Bridgehead Security Consulting, also stressed the value of collaboration, decrying organizations that have dropped out of industry groups because management didn’t understand the value.

“They’re crazy,” he said. “You don’t learn anything hanging around the office. You learn from meetings like this.”

Building on GridEx Lessons

Tim Conway, SANS Institute | © ERO Insider

Tim Conway, technical director for SANS Institute’s ICS and supervisory control and data acquisition programs, suggested utilities participate in NERC’s biennial GridEx to get tested by “surprise” scenarios and work in the off-years on the risks to which they are most vulnerable.

Conway said the industry can sound “schizophrenic.”

“We say these standards are a baseline minimum, indicating we should all be doing more. But because they’re changing so much, you’re not incentivized to do more because you’d be misallocating capital.”

Ben Miller, vice president for professional services and R&D for Dragos, a security firm focused solely on ICS, said, “There’s a difference between incident response planning and readiness.

Ben Miller, Dragos | © ERO Insider

“And largely what we’ve been testing to date with GridEx, I would say, is largely on the planning side. Being able to measure and understand readiness is a whole different ballgame.

“I do recognize that GridEx does do interdependency testing,” he continued. “I am suggesting from a threat assessment and threat understanding [perspective], we can sometimes close our eyes to the external facing threats that we don’t control because they’re hard to approach. That said, there’s still very realistic … scenarios that [suggest] some level of planning and discussion should happen outside of exercises.”

DER Risks and Benefits

Several speakers mentioned the potential risk from distributed energy resources.

Ben Blakely, Hydro One | © ERO Insider

“If we look at … our infrastructure … there’s visibility right at the edge that we don’t have for certain types of cyber issues,” said Ben Blakely, chief security officer for Hydro One. “You can’t manage scenarios that you’re not aware of.

“I’d be curious to see how other folks are doing in that space and also how it would be manifest in a certain scenario that would have impacts on the distribution and transmission system, and ultimately the customer,” he added.

Conway said DERs provide both risks (lower defenses) and potential benefits (the ability to island during disturbances). “We’re in this weird in-between zone right now,” he said.

Filtering out the ‘Noise’

Jason Stenstrom, Entergy | © ERO Insider

Jason Stenstrom, Entergy’s director of detection and response, said heightened awareness of cyber risks has also increased the volume of the “noise” with which he must contend.

“Not to say that is bad, because we’re building the culture where people are being aware of all these potential threats, but it can create quite a bit of noise,” he said. “Our CEO … will hear something … and [the question] will come right down to our CIO and right down to me: ‘What are we doing about this?’ It may not even be relevant to our environments.”

Market Systems’ Vulnerability

Blakely was asked how vulnerable the grid would be if the Ontario Independent Electricity System Operator’s market systems were unavailable or corrupted.

“We actually exercised this a few years back in a GridEx scenario,” he responded. “And one of the things we identified was, sure, we understood the criticality of the settlements and markets processes, but we’re not applying the appropriate controls consistent with where the other crown jewels are — at that point in time, the ESP [electronic security perimeter]. So, we actually started to put plans in place to harden that portion of the infrastructure.”

Blakely said Ontario can operate the power system without the market functioning, having a way to process settlements afterward. Still, he said, “It’s absolutely concerning. I don’t think it’s fully explored.”

GridSecCon included a trade show floor with vendors selling software and hardware to protect critical infrastructure. | © ERO Insider

Gas-electric Nexus

Kathy Judge, head of U.S. physical security for National Grid, talked about the difference between reliability regulation of the oil and natural gas (ONG) industry and that of the electric grid, which answers to NERC.

Kathy Judge, National Grid | © ERO Insider

“On the ONG side, we have many parents we have to answer to, and they don’t always agree in their approaches,” she said. “They each have their own regulations. … We have TSA [Transportation Security Administration] for pipeline security guidelines; we fall under the Department of Transportation under PHMSA [Pipeline and Hazardous Materials Safety Administration] regulations and DHS for [counterterrorism] standards. We’re under FERC in some situations. Each state regulates us, and then the U.S. Coast Guard [does so] as well. So, you can have a situation one week where you can have three different regulators come to look at the same site. So, not always ideal from an operational perspective.”

The positive: Gas regulations are “much less prescriptive” than NERC’s, Judge said. “We like that.”

Robert Mims joined Southern Co. as director of security for its gas, nuclear, generation and transmission operations, after the company’s acquisition of AGL Resources (now Southern Company Gas) in 2016. He confessed to having “NERC envy” when he was responsible for gas alone.

Robert Mims, Southern Co. | © ERO Insider

“I would see my electric peers and see all the resources they had to apply to the same problem that I did. But they’re serving 4.2 million customers with 30,000 employees, and they’ve got a team of 100 cybersecurity people. And I’m dealing with the same circumstances [with fewer resources] … so, it’s a challenge,” he said. “I don’t have regulations; I have pipeline security guidelines that are voluntary. If it takes a regulatory action to get me those resources, I’m all for it. That’s one way of looking at it.”

He recalled the 1965 blackout that led to NERC’s formation and the 2003 outage that caused Congress to authorize mandatory reliability standards for grid operators.

The gas industry knows “we’re one incident away [from mandatory regulations],” he said. “In the meantime, we’re going to keep working together, with a lot of industry collaboration, a lot of partnerships, and just understand our own risk and threats and doing what we think is the right thing for our companies to mitigate those risks.”

Not Sleepless in Idaho Falls

Several of the panel discussions included that hoary question, “What keeps you up at night?” Although the security of 5G technology concerns him, INL’s Tudor insists he sleeps well.

“I like to say, ‘I’m from Idaho Falls and I sleep like a baby, [thanks to] that fresh air and everything else,’” he said. “A lot of us have been here and doing this for a long time, and we’re really getting better. So, yeah, the adversaries are getting more sophisticated, but our community’s growing. We’re learning more, so it makes me hopeful every day. So, I don’t try to take it to bed with me. I just wake up energized to do more the next day.”

— Rich Heidorn Jr.