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December 26, 2025

Colo. AQCC Approves Deal on Pneumatic Devices

Colorado’s Air Quality Control Commission last week enacted the nation’s strictest rules around methane emissions from the pneumatic controllers used in oil and gas production facilities.

The AQCC unanimously approved revisions to Regulation Number 7 regarding the devices during a virtual hearing on Thursday. The hearing addressed issues bifurcated from the December 2020 rulemaking on Regulations 3 and 7 concerning the state’s Ozone State Implementation Plan.

Conservation groups, local governments and industry leaders joined forces to create and present a proposal endorsed by all stakeholders involved.

“We are pleased to be able to say today that after months of negotiations, we have reached a historic compromise proposal. … We’re excited to report that we’ve resolved all of the outstanding issues related to the rule language,” said Earthjustice attorney Robin Cooley, who represented the conservation groups during the hearing.

Pneumatic Devices and Past Policy

David McCabe of the Clean Air Task Force described the role of pneumatic devices in current oil and gas production to the commission. He said the devices monitor process parameters — metrics like temperature, pressure and liquid level — and use pressurized gas to send signals to regulate these parameters.

“Pneumatic controllers have long been identified as a very significant source of methane and VOC [volatile organic compound] emissions because when they use compressed natural gas to operate, they vent that gas and the methane and VOC it contains into the air.”

The devices are designed to emit natural gas during normal operations, but equipment malfunctions can cause leaks leading to even higher levels of emissions. In 2017 the AQCC adopted a “find and fix” program that required oil and gas operators to regularly inspect pneumatic controllers using an approved instrument monitoring method to determine if they were operating properly. It then adopted provisions to strengthen this program in 2019.

But “find and fix” was created to reduce excess emissions from these devices rather than eliminate them altogether.

“The compromise proposal requires the use of non-emitting controllers at new facilities, and it would make Colorado the first state in the country to require retrofits of existing oil and gas well production facilities and compressor stations with non-emitting controllers,” Cooley said.

Non-emitting controllers serve the same function as their emitting counterparts, but they function using pressurized air or electricity, McCabe said. He said that in 2019, more than 100,000 emitting controllers were producing methane in Colorado, but the new rulemaking states that any well production facility or gas compressor station built after May 1 may only use non-emitting devices. It also requires operators to retrofit devices at older facilities if they plan to undertake large projects that would increase their emissions production.

Industry Requirements

Colorado’s Joint Industry Working Group presented the proposal’s requirements for existing oil and gas facilities. Group representative Jennifer Biever said current operators will have to submit a company-wide plan on how they intend to reduce or phase out emitting controllers.

“The reason for the company-wide plan is that it affords operators compliance flexibility really to identify those facilities where retrofit of emitting controllers is feasible — both economically and technically — and more effective in achieving reductions of emissions,” Biever said.

According to the presentation, operators can reduce the use of emitting controllers by converting them to non-emitting controllers or by “plugging and abandoning an existing well production facility.”

Operators should be able to show significant reductions in the use of emitting controllers by May 2023.

Exemptions

Environmental Defense Fund representatives presented on exemptions to the rulemaking.

“These exemptions are designed to minimize the use of emitting controllers while permitting their use for necessary and reasonable purposes,” Sarah Judkins said.

The three exemptions are for emitting controllers:

  • necessary for “safety or process purposes”;
  • used in “temporary or portable equipment”; and
  • used as “emergency safety devices or for artificial lift” if located on a distant wellhead.

Unanimous Endorsement

After each group presented, the commission commented and asked for further clarification. Commissioners complimented the proposal, acknowledging how rare it is for stakeholders to reach a compromise of this scope.

“It really is a remarkable achievement that I know took a lot of work. … As a commissioner, it’s really nice to have something come forward with no outstanding issues,” Commissioner Curtis Rueter said.

To close, Commissioner Elise Jones, hearing officer for the proceeding, entertained a motion to approve the proposed revisions, which the commission unanimously endorsed.

‘Future Grid’ Session Highlights Tx Study, Net Carbon Pricing

The NEPOOL Participants Committee’s first working session on the “Pathways to the Future Grid” effort last week featured ISO-NE’s proposed work on market frameworks, including a long-range transmission study and examination of net carbon pricing.

The “pathways” effort is part of New England’s Future Grid Initiative, which also includes a reliability study. A stakeholder-developed framework document for that study was presented to a joint meeting of NEPOOL’s Markets and Reliability committees in December. (See New England ‘Future Grid’ Study Takes Shape.)

On Thursday, ISO-NE COO Vamsi Chadalavada discussed the RTO’s approach to conducting Phase I of the reliability study and a transmission study.

The New England States Committed on Electricity last year released a vision statement calling for ISO-NE to adopt an updated transmission planning process to help the region expand its grid to incorporate wind, hydro and distributed energy resources.

Chadalavada said the 2050 Transmission Study would develop high-level scenarios to evaluate large-scale renewable energy integration and cost estimates. It would also look far beyond the RTO’s typical 10-year horizon for transmission needs but not outline any plans for specific projects.

ISO-NE Future Grid
ISO-NE control room | ISO-NE

He also said ISO-NE will analyze implementing a Forward Clean Energy Market (FCEM) or Integrated Clean Capacity Market as well as net carbon pricing, ideas Rutgers University professor Frank Felder presented to the Participants Committee in January. (See Report Outlines NEPOOL ‘Pathways’ to a Future Grid.)

The RTO has championed incorporating net carbon pricing into its market to supplement the Regional Greenhouse Gas Initiative (RGGI) carbon price, but states adamantly oppose such a move.

Net carbon pricing would require stakeholders to agree on a social cost of carbon, from which the RGGI price would be subtracted. ISO-NE would then charge emitting generators the resulting additional cost of carbon and rebate associated revenues back to load-serving entities.

The plan would mitigate — but not completely solve — the double payment issue that arises when clean resources earn payments from both subsidies and market revenues.  It would also reduce states’ ability to control the specific timing and type of clean energy resources to meet their individual policy objectives — and additionally fails to explicitly address the balancing resource issue.

ISO-NE expects to provide more details on a potential net carbon pricing framework at the March working group meeting, according to Chris Geissler, economist for the grid operator.

The RTO also expects to complete the four analyses and studies by the first quarter of 2022. It has dedicated resources and budget to work with stakeholders to finalize scope and assumptions, develop models and run simulations, then present and discuss results of the four efforts, Chadalavada said.

But while ISO-NE could perform that work and respond to FERC orders, the complete effort could significantly strain the RTO’s operating budget, Chadalavada said. If new priorities emerge, the RTO would seek to rebalance its work and discuss that with stakeholders, he said.

Chadalavada concluded that Phase II of the reliability study would require modeling improvements. Inverter technology is rapidly evolving from “grid following” to “grid forming,” and the RTO has been working with NERC and industry vendors to develop and test the necessary models and tools.

Chadalavada said ISO-NE thinks it prudent to let some of these efforts mature before engaging in a longer-term system security study that would be part of Phase II. The pathway analyses will require building at least two models, one each for net carbon pricing and FCEM. This should determine how the Minimum Offer Price Rule (MOPR) will be treated in the modeling assumptions to assess how it affects the proposed frameworks’ outcomes. FERC has recently made clear that addressing the MOPR is one of its top priorities.

Rehearing Denied in PPL ROE Case

FERC last week denied a request for rehearing by PPL of the commission’s Oct. 15 order that established hearing and settlement judge procedures in a complaint over the company’s base return on equity methodology (EL20-48).

On May 21, the PP&L Industrial Customer Alliance (PPLICA), an ad hoc group of PPL commercial and industrial customers, filed a complaint that alleged the company’s 11.18% base ROE was unjust and unreasonable and argued it should be 8%. On June 10, PPLICA filed a supplement to the initial complaint to reflect revisions to the commission’s ROE methodology developed in Opinion 569-A, recommending a replacement ROE of 8.5%. (See FERC Ups MISO TO ROE, Reverses Stance on Models.)

FERC PPL Case
Susquehanna Steam Electric Station operated by PPL | Jakec, CC BY-SA 4.0, via Wikimedia Commons

In the October order, FERC found that because PPLICA’s initial complaint was complete when it was filed in May, “consistent with the commission’s general policy of providing maximum protection to ratepayers,” the refund effective date would be set at the earliest date possible of May 21, the date of the PPLICA’s initial complaint.

PPL asserted that the commission’s determination that PPLICA’s initial complaint was complete when filed was arbitrary and capricious, with the company contending that the decision was unsupported by record evidence and FERC precedent.

“We continue to find, as set forth in the order on complaint, that PPLICA’s initial complaint was complete when filed,” FERC said. “As an initial matter, the commission’s issuance of Opinion No. 569-A did not render PPLICA unable to ‘move forward with the initial complaint’ or make it ‘likely’ that the commission would ‘have rejected PPLICA’s complaint’ without PPLICA’s supplement.”

CAISO Speeds Rule Changes to Avoid Shortfalls

CAISO issued a draft final proposal for its summer readiness market enhancements initiative on Thursday, just three weeks after presenting a straw proposal in the form of a slide deck — not the usual written plan — because of what it said were time constraints.

The ISO held a virtual meeting Monday to discuss the draft final proposal and is pushing ahead to have the Board of Governors approve it before the end of March, with implementation scheduled for June 1. Passing a stakeholder initiative that quickly shaves at least a year off the usual deliberative process.

The extraordinary speed with which CAISO is advancing the initiative stems from last summer’s energy emergencies, including the rolling blackouts it ordered in August, and its need to avoid further capacity shortfalls this summer. (See CAISO Advances Summer Readiness Plan.)

At the start of Monday’s meeting, COO Mark Rothleder made an impromptu speech asking stakeholders to understand the urgency of the situation and the shortened timeline that has left some frustrated. He said CAISO management has taken stakeholder concerns seriously but must keep moving forward as expeditiously as possible.

CAISO Summer Readiness
CAISO is trying to prevent shortfalls after solar power wanes in summer heat waves. | Shutterstock

“These are very important and, in some cases, contentious issues that we’re grappling with,” Rothleder said. “I understand that not everybody is going to like where we landed … but I want to assure you that we have tried to balance as much as we could under the time frame for this summer. What we’re proposing here is really coming to the limits of our ability to execute and implement for this summer.”

The plan responds largely to a root-cause analysis of the state’s Aug. 14-15 blackouts, which identified problems such as transmission constraints, questionable exports from the ISO during tight supply conditions and market practices that undermined supply. (See CAISO Says Constrained Tx Contributed to Blackouts.)

The initiative’s proposed enhancements focus on the often-arcane market practices that CAISO determined interfered with resource adequacy. Its goals include meeting load in the ISO’s balancing authority area this summer, providing incentives for supply during tight system conditions, and “equitably [balancing] the reliability of serving CAISO … load with the reliability of exports, while providing open access to the CAISO transmission system.”

The plan includes measures dealing with export and wheeling priorities such as using the ISO’s residual unit commitment process to distinguish between high-priority and low-priority exports. It also proposes modifying the scheduling priority of wheel-through self-schedules across the CAISO balancing authority area so they have equal priority with high-priority exports.

The plan addresses issues related to CAISO’s Western Energy Imbalance Market, including upgrades to resource sufficiency tests intended to prevent participants from “leaning” on the market when they do not have sufficient supply.

“CAISO proposes to enhance the resource sufficiency evaluation by making … changes to its bid range capacity test that will account for resource derates and rerates, ensure imports represented through mirror resources are not double counted [and] include load uncertainty within each balancing authority area’s bid range capacity requirement,” the draft final proposal says.

Sticking to Principles

Market incentives for imports during tight system conditions, including provisions for make-whole payments for real-time imports, also are part of the plan.

Making sure that storage resources maintain a minimum state of charge is another plan component. Storage of solar power is essential for CAISO to meet demand in heat waves during the net peak, as the sun sets but demand remains high in the early evening. The August blackouts and close calls over Labor Day weekend occurred in the net peak.

There are currently 550 MW of storage connected to CAISO’s grid but 1,800 MW are expected by summer.

Rothleder and others said several items had been removed or scaled back in response to stakeholder comments, including deleting an item that would have made system market power mitigation part of the proposal. But the time for further changes is ending, he said.

“We have to start preparing for this summer, and we have to balance things out, and we have to be principled about what we’re doing here,” Rothleder said. “We believe this is a fair and an appropriate approach for this summer. We understand that there may be some additional things that people would want to do if we had more time. We are open to that for the future, but we’ve got to start moving in the direction of implementing these things.”

A separate resource adequacy enhancements initiative is advancing on a similarly fast track, with a meeting scheduled Tuesday on a draft final proposal.

The EIM Governing Body is scheduled to take up the plan on March 10 followed by the ISO’s Board of Governors on March 24-25.

Texas PUC Turns Focus to Customer Bills

In a twist of irony, Texas Public Utility Commission Chair DeAnn Walker found herself sitting in a chilly, darkened hearing room Sunday as she opened the commission’s second emergency open meeting of the weekend.

The state’s facilities group had turned down all the heating and nearly all the lights — except for safety lighting — in government buildings following last week’s power outages, Walker explained.

The PUC then set about its business, issuing a set of orders intended to protect Texas electricity customers and prevent possible disconnections for non-payment on Monday. The directives immediately suspended disconnections until further notice and extended a COVID-19 measure that requires retail electric providers (REPs) to offer deferred payment plans upon request.

The orders only apply to customers of investor-owned utilities under the PUC’s jurisdiction: American Electric Power Texas, CenterPoint Energy, Oncor and Texas-New Mexico Power.

Texas Customer Bills

PUC Chair DeAnn Walker convenes the open meeting Sunday with only safety lighting. | PUCT

The commissioners also urged REPs to delay invoicing for residential and small commercial customers. The IOUs rely primarily on automated meters that, in the case of a long-term outage, estimate meter reads based on historical usage.

“We may end up doing this every day,” Walker warned her fellow commissioners. “Every day, a new rock may be turned over that requires us to take action.”

On Friday evening during a hastily called meeting, the PUC waived deadlines surrounding its provider-of-last-resort (POLR) program, where REPs volunteer to accept customers from other providers exiting ERCOT’s competitive market. These “volunteer” REPs are required to charge a competitive rate, rather than the higher POLR rate.

The move was driven by concern that some of the more than 100 REPs in the market may go under after wholesale prices reached $9,000/MWh during the cold snap and stayed there for much of the time.

“I’m happy these customers will have a place to go,” Commissioner Arthur D’Andrea said. “I don’t want any of them to get on a bad POLR plan. They shouldn’t have to deal with that now.”

Vistra’s TXU Energy and NRG Energy’s Reliant Energy, which together account for more than 70% of the retail market, are likely to benefit from the changes.

Horror stories abound of four-figure bills hitting customers who signed up with REPs that pass on wholesale real-time prices. Griddy grabbed most of the headlines by serving one customer a $16,752 bill.

The company’s CEO, Michael Fallquist, said Griddy was designed for an energy market that “allows consumers the ability to plan their usage based on the highs and lows of wholesale energy and shift their usage to the cheapest time periods.”

Texas Customer Bills

Griddy’s CEO shared a message sent to customers alerting them to high rates. | Griddy

Indeed, Griddy did warn its 29,000 customers as the winter storm approached to consider switching to other REPs.

For its part, TXU Energy assured its residential customers that they would not see any “near-term impact” because of the winter weather event, though some might experience above-normal bills because of higher usage.

“The headline-grabbing sky-high bills are related to wholesale plans offered by some providers; TXU Energy does not put its customers at risk by offering these plans,” TXU President Scott Hudson said in a statement.

On Saturday, Texas Gov. Greg Abbott convened a bipartisan virtual meeting with 11 state legislators to begin discussions on how to insulate customers from electricity plans linked to wholesale prices.

“It is unacceptable for Texans who suffered through days in the freezing cold without electricity or heat to now be hit with skyrocketing energy costs,” Abbott said before the meeting.

“Our absolute top priority as a commission and a state is protecting electricity customers from the devastating effects of a storm that already affected their delivery of power,” Walker said.

ERCOT, MPs Hit with Lawsuits

The first lawsuits have begun to roll in, targeting ERCOT and market participants for the non-rotating outages that left residents without power for at least 80 hours at a time.

In Houston, a trial lawyer filed a $100 million lawsuit against the ISO and Entergy Texas over the hypothermia death of an 11-year-old boy. Another lawsuit filed in Houston seeks $10 million from the grid operator and CenterPoint Energy for gross negligence. A third lawsuit filed in Corpus Christi asserts the grid operator and AEP Texas are responsible for property damage and business interruptions.

“We haven’t yet reviewed the lawsuits and will respond accordingly once we do. Our thoughts are with all Texans who have and are suffering due to this past week,” ERCOT said in a statement.

The legal efforts face long odds. ERCOT, a nonprofit government agency, enjoys sovereign immunity. The ISO has said it needs immunity from lawsuits because generators’ transaction fees fund the entity.

However, the Texas Supreme Court is expected to rule on a case later this year involving independent generator Panda Power and ERCOT that could eliminate that immunity.

FERC Approves PJM’s Immediate-need Revisions

FERC last week approved PJM’s proposed Operating Agreement language to provide more transparency in the conditions that exempt “immediate need” transmission projects from competition under Order 1000 (ER20-2686).

The commission first opened an investigation into PJM’s practices for designating immediate-need projects in October 2018, questioning whether it was opposing Order 1000’s competition mandate by misusing the exemption. (See FERC to Probe Order 1000 Competition Exemptions.)

Order 1000 allows a right of first refusal (ROFR) for transmission projects needed for reliability so urgently that there is insufficient time to hold a competitive proposal window.

The commission determined Thursday that PJM’s compliance filing “establishes a just and reasonable implementation structure for immediate-need reliability projects.” PJM had been ordered in June to make OA changes regarding language it developed to create a ROFR exemption. (See More Transparency Ordered on PJM ‘Immediate Need’ Tx.)

PJM Immediate-need Revisions
| © RTO Insider

Criteria Met

In its June order, FERC concluded PJM was complying with only two of the five criteria to limit the RTO’s discretion for applying the immediate-need exemption, saying it should be used only in “certain limited circumstances.”

Regarding the second criterion, FERC said PJM did not comply with a requirement that it separately identify and post an explanation of reliability violations and system conditions for which there is a time-sensitive need, including sufficient detail of the need and time sensitivity.

In Thursday’s filing, the commission determined that PJM’s proposed supplemental document providing details on each identified immediate-need reliability violation that the RTO proposes to exempt from the competitive proposal window process complied with requirements of the criterion. FERC also said PJM’s plan to both post the supplemental document on its website and include the supplemental document with Transmission Expansion Advisory Committee meeting materials met the criterion.

As an example of what the supplemental documentation would look like, PJM provided the compliance attachments for the Northern Neck Area and Manassas Area, two reliability violations the RTO identified as immediate need in 2020.

LS Power argued in a protest filing that the supplemental document should be part of “presentation” materials rather than “informational” materials. FERC said it was not persuaded by LS Power’s arguments and that it was satisfied with PJM’s solution.

“We expect PJM to adequately inform its stakeholders about all immediate-need reliability transmission projects such that transmission project-specific information will be included in the materials for TEAC meetings, included for discussion, and stakeholders will have opportunities to raise comments and questions about specific immediate-need reliability projects,” FERC said.

For the third criterion, FERC said PJM must provide a “full and supported written description” on any decision to award a project to an incumbent TO, including an explanation of other transmission or non-transmission options that the RTO considered and the cause of the need and why it was not identified earlier.

PJM proposed that the example attachments comply with the requirement to “provide a full and supported description of its decision to designate the immediate-need reliability project to the incumbent transmission owner, the alternatives considered and the circumstances generating the need, including why the need was not identified earlier.”

Protesters argued that the compliance attachments do not explain if other transmission and non-transmission alternatives were considered or why a time-sensitive reliability need was not identified earlier. LS Power also argued that the compliance attachments “make only sweeping statements about the reliability issues and the resulting determination that a competitive proposal window is infeasible.”

FERC said it agreed that PJM’s clarifications are “adequately responsive to these concerns” and that the compliance attachment for the Manassas Area specifically identified why a reliability need was not identified earlier. FERC did say PJM acknowledged that it “did not explicitly provide discussion of the alternative transmission and non-transmission options” considered in the attachment.

“In all future supplemental documents, we expect PJM to include an explicit explanation of other transmission or non-transmission options that it considered before designating an immediate-need reliability project,” FERC said.

Finally, in the fourth criterion, FERC said stakeholders must be permitted time to provide comments in response to the project description and the comments must be made publicly available. The commission had found that PJM providing three days for stakeholders to review immediate-need reliability project materials was not an adequate amount of time.

PJM proposed to revise the OA to add a specific period of “no less than 10 days” for stakeholders to review the meeting materials and transmission project-specific supplemental documents.

“We find that PJM’s proposed revisions are just and reasonable given the time-sensitivity of the reliability violations being addressed by proposed immediate need reliability projects,” FERC said.

DC Circuit Upholds FERC on ITC Adders

The D.C. Circuit Court of Appeals on Friday upheld a FERC ruling that found a 2016 merger had left three ITC Holdings subsidiaries no longer fully independent, disqualifying them from a full return on equity incentive for standalone transmission providers.

The decision found there was “substantial evidence to support FERC’s finding that the merger had reduced ITC’s independence, thereby rendering the existing adders unjust and unreasonable” (International Transmission Company, et al. v. FERC, 19-1190).

FERC had granted International Transmission Co. and Michigan Electric Transmission Co. 100-basis-point adders in 2003 and 2005, respectively, and granted ITC Midwest a 50-point adder in 2015. But in October 2018 the commission found the companies were no longer fully independent because their parent company, ITC Holdings, had merged with Canadian and Singaporean companies (EL18-140).

FERC ITC
ITC Midwest has been upgrading transmission in Iowa. | ITC

FERC reduced their “transco” adders to 25 basis points each. (See FERC Reduces ITC Adders over Independence Issues.)

The commission affirmed its ruling in July 2019, saying the reduction in the adders was appropriate because the merger had reduced but not eliminated the companies’ independence. (See FERC Rebuffs ITC Call to Restore Full ROE Adders.)

The transmission companies appealed to the D.C. Circuit. They argued FERC had “arbitrarily and capriciously departed from precedent establishing a particular methodology to assess transco independence.” And they contended FERC had “exceeded its statutory authority by reducing ITC’s transco adders without first finding the adders to be unjust and unreasonable,” according to the court.

Regarding the first argument, a three-judge panel found it “fails at the outset because FERC, consistent with its stated intent in Order No. 679, never established any definitive methodology, let alone the one ITC claims it did.”

“FERC has consistently applied a case-by-case approach to determining transco independence, considering ownership and business structure as part of that inquiry since it first granted a transco adder in 2003,” the court said.

The companies’ claim that FERC had exceeded its statutory authority under Section 206 of the Federal Power Act also failed, the court found.

The law requires “FERC to show that an existing rate is unlawful before ordering a new rate,” and ITC argued that FERC had violated that mandate by failing to find the existing adders to be unjust or unreasonable before reducing them by half,” the judges wrote. FERC’s analysis, however, “clearly tracked the two-step procedure mandated by Section 206,” they said.

Counterflow: The Mess in Texas

ERCOT Blackouts
Steve Huntoon | Steve Huntoon

Nobody outside our industry understands our industry. And we see ourselves  through a glass, darkly.

So with the tragedy in Texas (more specifically ERCOT, which is 90% of Texas’ load), there are plenty of politicians and talking heads spinning what happened and who or what is to blame. They’re mostly wrong.

There are two things not to blame. And two things to blame. Please let me explain.

Thing No. 1 not to Blame: Wind Generation

Yes, there is a lot of wind in ERCOT: around 30,000 MW. And yes, wind is intermittent.

That’s why ERCOT assumes that only a small fraction of maximum wind generation will be available when needed. The amount of available wind that ERCOT assumed this winter is 7,070 MW.[1] And ERCOT ran a sensitivity for low-wind output that assumed 5,279 of that 7,070 MW would not be available, leaving 1,791 MW available.

Now let’s look at what actually happened. This chart, “ERCOT Load vs. Actual Wind Output,”[2] shows that actual wind generation (the right vertical axis, in megawatts) during the Feb. 11-18 period had only two brief dips below the low-wind sensitivity of 1,791 MW.

ERCOT Blackouts
ERCOT load vs. actual wind output Feb. 11-18 | ERCOT

So wind generation is a bit player in this tragedy.

Thing No. 2 not to Blame: Load Forecast

In the fall ERCOT forecasted an extreme weather winter peak load of 67,208 MW.[3] Now let’s look at the same chart showing ERCOT load during Feb. 11-18 (this time the left axis). The peak load was 69,222 MW, at 8 p.m. on Feb. 14.[4] This is only 2,000 MW more than the forecasted extreme weather peak load, and this forecasted peak was exceeded for only five hours.

Now to complete the picture, we need to recognize that early in the morning of the next day, Feb. 15, ERCOT began shedding load. So we would need to add back load shed in order to simulate unrestricted load. The load shed began at 10,500 MW at 1:25 a.m., and grew to 16,500 MW later that day.[5] If you look at the chart and envision the addition of the load shed, you’ll see that the unrestricted load does not exceed the peak at 8 p.m. on Feb. 14 of 69,222 MW.[6]

So the load forecast is also a bit player in this tragedy.

Thing No. 1 to Blame: Thermal Generation Maintenance Outages

Now we’ll discuss the real culprits: thermal generation (gas, coal and nuclear) or, more accurately, the lack thereof.

Two things went wrong with thermal generation: maintenance (planned) outages and forced (unplanned) outages.

ERCOT Blackouts
Texas RE-ERCOT Seasonal Risk Scenario | NERC

To understand what happened with the first thing, please look at the chart “Seasonal Risk Scenario,”[7] which was prepared by the NERC in November 2020 from data provided by ERCOT. This is a “waterfall” chart starting with gross winter resources on the left side, and then making adjustments to arrive at expected net resources relative to extreme winter peak demand on the right side. As you can see, ERCOT forecasted an expected operating reserve of 2.3 GW under extreme conditions.[8]

If you look at the second bar from the left, ERCOT forecasted 4.1 GW of “typical maintenance outages.” Here’s the problem: ERCOT approved 14 GW of maintenance outages for this period,[9] about 10 GW more than it had forecasted.

This appears to be grid operator error.

Thing No. 2 to Blame: Thermal Generation Forced Outages

Now to thermal generation forced outages. Please look at the same chart, this time the third and fourth bars from the left. The third bar shows “typical forced outages” for thermal generation of 4.5 GW, and the fourth bar shows “derates” (outages) for “extreme conditions” for thermal generation of another 4.5 GW. The total is 9 GW, which is the forced outages for thermal generation under extreme conditions.[10]

Actual thermal generation forced outages: about 18 GW.[11] So actual forced outages were 9 GW more than ERCOT’s extreme conditions scenario.

To recap, there were 10 GW of excess maintenance outages and 9 GW of excess forced outages, for a total of 19 GW in unanticipated thermal outages, in line with the necessary load shed of 16.5 GW.

The Why

As I said earlier, the excess maintenance outages appear to be grid operator error.

But what about the excess forced outages? Extreme winter conditions regularly occur around the U.S. and the world without catastrophic loss of electric generation.

ERCOT has a market design that assumes that as long as wholesale prices are unlimited, supply and demand will always “clear” — basically equalize. New resources will be built and upgraded in anticipation of occasionally getting very high prices. And existing resources would incur new capital costs in order to receive those very high prices occasionally.

The problem has always been that the needed high prices occur rarely — like every 10 years — when they max out at $9,000/MWh, 360 times a typical wholesale price of $25/MWh. Who would finance and build needed resources and their winterization on such a GameStop bet? And when such prices do occur, the political, regulatory and market fallout can be staggering.[12]

Because of these real-world limitations, grid operators like PJM have adopted a hybrid market structure: a capacity market to assure that adequate resources will be available when needed, and an energy market that matches supply and demand on a least-cost basis every hour.

A capacity market spreads the needed compensation to maintain, build and secure adequate supply resources over every day, month and year instead of requiring speculation over a burst of revenue that happens maybe once every 10 years. And it penalizes any resource that does not perform when needed. The cost to customers is spread over time instead of unpredictable price surges maybe every 10 years.

It’s a form of insurance: You don’t need it until you need it.

As The Economist observed:[13]

“Perhaps most important, the state [Texas] does not have a ‘capacity market’ to ensure that there was extra power available for surging demand. Such systems elsewhere act as a sort of insurance policy so the lights will not go out, but it also means customers pay higher bills.”

Let me close by wishing the best to the good people of Texas, and the hope that we all learn the right lessons from this tragedy.


[3] Same as footnote 1.

[5] ERCOT news releases, http://www.ercot.com/news/releases.

[6] A Rice University atmospheric scientist estimated the unrestricted load at about 70,000 MW. https://www.popsci.com/story/environment/texas-power-outages/. The consultancy Enverus forecasted peak load on Feb. 15-16 of 66,000 to 69,000 MW in a Feb. 12 webinar. https://www.enverus.com/blog/trading-and-risk/volatility-ahead-freezing-cold-sends-u-s-power-prices-higher/, at 6:20. The U.S. Energy Information Administration reports that ERCOT forecasted some hours above 70,000 MW. https://www.eia.gov/todayinenergy/detail.php?id=46836

[8] Wood Mackenzie points out that ERCOT does not combine extreme conditions of high thermal outages and low wind when comparing to extreme winter peak load.

[9] https://www.woodmac.com/news/editorial/Breaking-down-the-texas-winter-blackouts/full-report/. Wood Mackenzie also reports that in the week before the storm hit, ERCOT tried to recall some of this generation but was not successful in doing so. Although Wood Mackenzie described all 14 GW as “offline for maintenance,” it is possible that some of that were forced outages, in which case that portion should be added to excess forced outages discussed in the next section. ERCOT apparently does not have the literal power to reject planned outage requests submitted more than 45 days in advance, but it is difficult to believe that a generator would insist on its timing if ERCOT advised that system reliability would be denigrated.

[10] Wood Mackenzie points out that ERCOT does not combine extreme thermal outages and the low-wind sensitivity when comparing to extreme winter peak load and that, if ERCOT had done so, it would have shown a negative operating reserve of 4 GW.

[11] Wood Mackenzie reports that total thermal outages the morning of Feb. 15 went from the 14 GW of maintenance outages to 32 GW, the difference being 18 GW of forced outages. A chart stacking forced outages on top of maintenance outages is in an article by Enverus here, https://www.enverus.com/blog/trading-and-risk/ercot-power-grid-outage-what-went-wrong/.

ISO-NE Planning Advisory Committee Briefs: Feb. 17, 2021

Eversource Energy and Vermont Electric Power Co. (VELCO) each presented replacement and refurbishment projects to the ISO-NE Planning Advisory Committee on Wednesday, with Eversource detailing its preferred solution to replace the only self-contained fluid-filled cable on its Connecticut transmission system.

Eversource’s Paul Melzen said the utility plans to remove 400 feet of the existing cable system and install 520 feet of solid dielectric cable in the duct bank at Branford 11J, a 115/23-kV substation located along the Connecticut shoreline. The project also calls for replacing two existing bus support structures and the relocation of an NRG Energy-owned 23-kV circuit from a combustion turbine housed in the substation to accommodate the route of the 115-kV duct bank.

The work’s estimated cost is $8.8 million, with a projected in-service date in the fourth quarter.

The fluid-filled cable was initially manufactured in 1981, and its creators are no longer in business. The cable has logged 26 work orders since 2005, including fluid leaks that increased maintenance burdens and reliability concerns. The continued decrease in oil pressure or oil level will eventually result in a trip of the cable. There was a service interruption in March 2017 that required complex restoration methods, according to Melzen. The cable is also located near a waterway, an environmental risk.

ISO-NE

Eversource Energy wants to replace a self-contained, fluid-filled cable system with a solid dielectric cable system at a substation in Branford, Conn. | Eversource Energy

Melzen mentioned two potential alternatives to Eversource’s preferred solution. One is replacing the existing fluid-filled cable system with a new one, which would create the need for dielectric fluid accumulators, fluid-level pressure alarms, and additional maintenance and operational requirements. It would additionally pose an environmental threat with the release of dielectric fluid. There would also be limited equipment suppliers. The second is replacing the current cable system with an overhead bus, but there is a lack of real estate in and around the substation to accommodate it.

Hantz Presume of VELCO outlined three transmission line refurbishment projects at an estimated cost of $31.6 million, with the work completed between 2022 and 2024.

The most significant portion of the work will be along the 26.4-mile line from Essex to Middlesex, where 116 out of 305 wood H-frame structures with rotten pole tops and cross arms will be replaced with mostly steel H-frames to reduce VELCO’s current wood pole inventory. The line location is primarily mountainous, with difficult access and a challenging sloped right of way. The estimated cost is $15.2 million for the project, which is expected to be completed in 2024.

The other two projects are similar refurbishments along lines between Essex and Sandbar (11.2 miles) and West Rutland to Blissville (11.6 miles) that are expected to cost a combined $16.4 million and replace a total of 123 wooden frames with steel by 2022. Both lines have seen rotten crossarms and pole tops, and moderate to severe woodpecker damage.

Additional Items

  • ISO-NE Director of Transmission Planning Brett Oberlin gave a forward-looking presentation on dynamic reactive power devices. The RTO would like to use synchronous condensers as the preferred device to address system concerns identified in needs assessments, except under specific system limitations. Oberlin asked for stakeholder feedback by March 4.
  • Steven Judd, principal engineer in system planning for ISO-NE, provided stakeholders a summary of DNV GL’s stochastic time series analysis of variable energy resources (VERs). The RTO initially hired DNV GL in 2019 to use its weather modeling software and develop a historical dataset of all existing wind plants and future offshore wind plants from 2012 to 2018. It now contains hourly time series data for VERs, load and weather data in New England for 20 years (2000-2019). DNV GL also developed the Stochastic Engine, which can resample wind speed, irradiance, price and load into parallel and plausible scenarios. The weather-to-generation models simulate each weather scenario’s expected power production, creating thousands of 20-year simulations of hourly weather and power outputs.

SPP RSC Finalizes Recommendations for SLC

SPP’s state regulators recently agreed on revisions to a package of recommendations that would improve operations along the RTO’s seam with MISO.

Texas Public Utility Commission Chair DeAnn Walker facilitated the Regional State Committee’s modifications to the document, which prioritizes resolving rate pancaking and adds a category for smaller interregional projects. (See RSC Keeps MISO Liaison Committee Alive.)

The RSC, meeting on Feb. 12 shortly before severe winter weather overwhelmed many of its members’ states, agreed that rate pancaking and smaller interregional projects should remain their two top priorities.

SPP rate pancaking
The MISO-SPP seam | Organization of MISO States

The regulators also agreed that the RSC-Organization of MISO States Seams Liaison Committee (SLC) should create a working group focused on inventorying the different types of rate pancaking along the MISO-SPP seam and sided with the SLC’s recommendation that a survey be conducted of transmission owners and other stakeholders to measure interest in studying the issue.

“Creating that inventory is important,” Kansas Corporation Commissioner Andrew French said. “It’s important to get feedback from the TOs and other stakeholders. It’s not just TOs experiencing those issues.”

The SLC has said the working group should comprise RSC and OMS members and an equal number of other stakeholders chosen by the two regulatory groups.

Walker, the RSC’s lead on the SLC, was to send the revised document to OMS Executive Director Marcus Hawkins.