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December 22, 2025

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New FERC Rules Sought on Transmission Planning

A group of former FERC chairs during a virtual panel discussion on Wednesday said the commission should issue new transmission planning rules to help decarbonize the U.S. and provide resilience and energy security.

Pointing to the success of previous landmark FERC orders, the former chairs said that while the specifics of what new rules might look like are not clear, the reasons for them are.

Former Chair Elizabeth Moler told the panel that she is proud of helping launch open transmission access with Order 888, but the transmission system has “changed dramatically in the intervening 25 years.”

FERC, she said, “should take the steps necessary to facilitate more access for new actors, new players, new types of resources, and interregional transmission, and encourage further development of an even more robust interdependent and new generation of power supply.”

The panel was hosted by Americans for a Clean Energy Grid (ACEG) for the release of its new report, “Planning for the Future: FERC’s Opportunity to Spur More Cost-Effective Transmission Infrastructure.” The report calls for FERC to issue a new rulemaking to reform planning, cost allocation and review of transmission in a manner that will support more regional and interregional power exchange for national energy security, reliability, resilience, cost-effectiveness and economic competitiveness.

“A decade after Order No. 1000’s issuance, the nation faces new challenges, and it is clear that neither the current infrastructure nor the rules governing its development match this need,” the report said.

The report supplements ACEG’s Jan. 12 report that alleged RTO policies assigning most costs of large network upgrades to interconnection customers violate FERC’s “beneficiary pays” principle and are no longer just and reasonable. (See ‘Participant Funding’ Violates FPA, Grid Groups Say.)

As part of the report, ACEG makes sweeping recommendations for how FERC could move forward with the rulemaking, but panel members did not specifically endorse the policy details of the report.

They were, however, generally supportive of the idea that proactive planning of regional and interregional transmission infrastructure is necessary in the near term.

“I believe [the grid] will need to double in size to accommodate electrification, transportation, heat and other industrial processes,” said former Chair James Hoecker, who formerly headed the transmission trade organization WIRES. “Even taking into account [distributed generation] and energy efficiency, the doubling of electricity from wind and solar between now and 2035 augurs very strongly for major expansion of the grid.”

Building on Success

Greg Wetstone, CEO of the American Council on Renewable Energy, also joined the panel discussion, saying that there has been no interregional transmission development using the Order 1000 process.

“I’m hopeful [FERC] will be able to address these issues with a new rule that will help modernize and expand our outdated and congested power grid,” Wetstone said.

The failure to bring new interregional transmission to development isn’t for a lack of trying. 4th Time No Charm for MISO-SPP Interregional Study.)

Former FERC Commissioner Nora Brownell said inconsistency between and among regions makes it difficult to make decisions in the planning process. She said that the industry has better data now than it had when she was at FERC in the early 2000s, and it could be better applied to planning.

“I’d love to see FERC not only broaden the data set by encouraging new transmission technologies but also working with [the U.S. Department of Energy] to analyze data to make sure that we are being consistent in how we apply things,” she said.

The ACEG report offers suggestions for how to build on the success of FERC Orders 888, 2000, 890 and 1000, allowing for the lessons learned from their implementation to expand development of “region-spanning and interregional transmission capacity,” with an eye toward cost effectiveness.

In the report, the vision for a new planning process takes shape under four suggestions.

      • Best Available Data: Planning processes would use the best available data and forecasting methodologies to ensure projects address future needs and scenarios. Planning entities would have to evaluate needs based on a range of factors that could influence long-term power demands and the resource mix.
      • Consider Benefits Together: Planning authorities would need to consider all the benefits of transmission together to avoid a siloed approach. The report says classifications of projects by reliability, public policy or economic status can overlook their multiple benefits.
      • Evaluate All Solutions: Transmission planning entities would be directed to evaluate all available solutions — including new physical infrastructure options and grid-enhancing technologies — within regional transmission plans. This approach, the report said, ensures that lower cost or better performing options are included in planning.
      • Plan with Portfolios: Transmission planning entities would select a portfolio of solutions for each regional and interregional transmission plan that is likely to maximize aggregate net benefits. The report said that FERC should encourage innovations to ensure accurate quantifications of transmission-related benefits to support portfolio planning.
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NRG Extends Petra Nova’s Mothballing Indefinitely

NRG Energy notified ERCOT Wednesday that it intends to indefinitely mothball its gas-fired Petra Nova Power generating unit, a change from its earlier determination to seasonally sideline the plant.

The move becomes effective June 26. NRG previously told ERCOT in September that Petra Nova would be operated annually on a seasonal basis, June 1 through Sept. 30. (See NRG to Mothball Petra Nova CCS Plant.)

The facility is part of the Petra Nova Project, the world’s largest carbon-capture facility. NRG suspended carbon-capture operations at the site in May, citing the “current status” of oil markets.

The project captured CO2 from the plant’s flue gas and funneled it through an 80-mile pipeline to a nearby oil field. There, the captured CO2 was injected into a depleted oil reservoir, softening up the residual oil and improving its flow.

Petra Nova became uneconomical when oil prices plunged last year as the global economy shut down in the face of the COVID-19 pandemic. West Texas Intermediate crude for March delivery settled at $52.85/barrel Wednesday on the New York Mercantile Exchange; $50/barrel is considered the breakeven marker.

The plant has a summer capacity of 71 MW.

ERCOT market participants have until Feb. 17 to file comments on whether the resource is necessary for reliability reasons.

Wind Farm to be Shut Down

ERCOT has also received a notification of suspension of operations for the 120-MW Sherbino 1 Wind Farm in West Texas. The facility ceased operations because of a forced outage and will be decommissioned and retired permanently on Feb. 1, the grid operator said.

Constructed in 2008, Sherbino 1 was a joint venture between NRG and BP Wind Energy North America. Castleton Commodities International acquired the wind farm in 2019.

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MISO Annual Transmission Spending Tracks Downward in 2021

The cost of MISO’s 2021 Transmission Expansion Plan is set to ring in substantially below last year’s spending level, the RTO revealed during its South subregional planning meeting Tuesday.

Proposed investment for MTEP 21 stands at $2.85 billion for 350 projects, substantially below MTEP 20’s final $4.05 billion spend for 493 projects. The relatively modest numbers do not include any possible projects under the grid operator’s long-range transmission plan, which will rely on MTEP 21 futures. (See MISO Begins Longterm Tx Modeling.)

Broken down, the draft MTEP 21 contains $723 million worth of baseline reliability projects, $331 million in generator interconnection projects and nearly $1.8 billion spend in the “other” project category, which includes other reliability projects, load growth projects, age and condition-based projects and projects driven by other local needs.

“All of this is preliminary. More information and details will be coming up,” Senior Manager of Expansion Planning Edin Habibovic said.

MISO will finish power flow modeling for MTEP 21 in late spring. After collecting transmission owners’ planning criteria last year, the RTO is now conducting assessments of proposed reliability projects to ensure they’re the most cost-effective solutions. It will also study member-submitted alternatives to project proposals, an effort expected to continue until May.

Making a Case for Long-term Transmission

RTO executives appeared before state regulators to bolster justification for its long-range transmission plan. The first such projects could be approved under MTEP 21.

“Roughly 85% of the footprint has some kind of clean energy goal,” Executive Director of System Planning Aubrey Johnson told state regulators during an Organization of MISO States teleconference on Monday. “This is not going to be achievable without some kind of transmission.”

Clean energy pledges from MISO states and utilities are accumulating quickly. Minnesota this week accelerated its 100% carbon-free electricity pledge by a decade, to 2040. However, the state’s two largest utilities, Xcel Energy and Minnesota Power, are still targeting 100% carbon-free goals by 2050.

MISO expects renewables to account for 25% of its capacity by 2039.

“The question becomes do you have sufficient arteries to deliver this power,” Johnson said.

Americans for a Clean Energy Grid this week compiled studies concluding that grid capacity should double or triple in the near future to reliably accommodate an evolving resource mix.

Johnson said MISO will consider lessons learned from its last long-term planning effort, the 2011 Multi-Value Project portfolio, in which projects were analyzed for benefits as a bundle, not individually. MISO has said projects resulting from its newest long-term plan will be assessed on an individual basis, though there is a chance that some complementary projects could be paired up and considered as one.

“It’s not lost on us the regulatory challenges of a portfolio of projects — some that didn’t get regulatory approval until 2019,” Johnson said, referring to the $492 million Cardinal-Hickory Creek line from southwest Wisconsin to Iowa, the last of the 17-project Multi-Value portfolio in line for a groundbreaking ceremony.

During a subregional planning teleconference on Jan. 27, Clean Grid Alliance’s Natalie McIntire said she’s interested in how MISO will avoid “corridor fatigue” with the long-term package, where the general public tires of dealing with new routes and construction.

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Panel: Industry Dialogue Key to Cyber Resilience

As the spread of distributed energy resources creates more opportunities for online attacks against the electric grid, industry experts are calling for fresh thinking to address emerging cybersecurity threats.

“A lot of people are very concerned, including me, but the sky isn’t falling; I’m confident [we’ll] figure it out,” Manny Cancel, senior vice president at NERC and CEO of the Electricity Information Sharing and Analysis Center, said in a panel at NERC’s Reliability Leadership Summit this week. “But … when you extend what this threat means across distributed resources, it … not only increases the attack vector, but … it holds us accountable. And we really have to think about how we build protection into the design of these systems going forward.”

The past two months have provided myriad examples of how “the risk is converging,” Cancel said, pointing to the unrest at the U.S. Capitol on Jan. 6 and the breach of SolarWinds’ Orion products that allowed hackers to gain access to multiple government computer networks, including the Department of Energy and FERC Pushes Cybersecurity Incentives.)

Vendors Emerge as Major Risk

Earlier this month, the FBI, the Cybersecurity and Infrastructure Security Agency, the Office of the Director of National Intelligence and the National Security Agency issued a joint statement saying the SolarWinds breach was “likely Russian in origin.” Panelists warned that the attack exposed some flawed assumptions in current security thinking that will need to be addressed to prevent future attacks.

“As a collective, [we] need to manage how we deal with vendors,” said Michael Russell, manager for the energy, finance and telecommunications sectors at the Canadian Centre for Cyber Security. “SolarWinds was an American vendor. You’re never going to catch an American vendor [if] country-of-origin testing [is] your only determination if something’s good or bad. We really need to … take in other factors, such as the sensitivity of the equipment, the technical characteristics and the life cycle that the equipment was developed under.”

The growing presence on the grid of internet-connected assets made by vendors with uncertain supply chain provenance is a potentially serious problem, warned Tom Galloway, president and CEO of the North American Transmission Forum. He gave an example of a class of inverters that were found to have a common flaw, but only after their misoperation — the kind of weakness that could present a “common mode of failure” exploitable by adversaries.

“You can imagine someone with a malicious intent figuring out a way to affect multiple devices like that simultaneously … and with the proliferation of new equipment on the system, I really think that we have to get our game on with supply chain,” Galloway said.

Security Benefits from Mutual Assistance

But the supply chain issues and other cybersecurity challenges are unlikely to be solved by the imposition of new requirements from FERC or other governmental bodies, Russell said, calling the impulse to control cyber threats through regulation “a bit of a race to the bottom.” Instead, regulators must find ways of encouraging utilities to build cybersecurity into their existing risk management processes so that they can internalize the risk and build their own solutions.

Michele Guido of Southern Co. agreed with the other panelists that the scope of the threats from online actors is still not fully known, and that industry-wide conversations are urgently needed in order to identify and prioritize the most pressing issues and plan for how to tackle them.

“I think … we had an absolutely incredible year in 2020. The power stayed on [and] we worked together, no matter what the situation,” Guido said. “But what are those things that we’re not thinking about? … What do the threat indicators look like, what are the warnings … and then how do we better partner with [the] public sector … and be proactive, not reactive to every event?”

Marilyn Brown, interim chair of the school of public policy at the Georgia Institute of Technology, confessed to feeling “nervous” about the rapidly shifting world of cybersecurity. On the other hand, she pointed out that the industry currently has a bit of unexpected breathing space and urged those present to take the opportunity.

“I may be naive, but it seems to me that with the pandemic and the slowdown in electricity consumption, we’ve had the luxury of a bit of tranquility, in terms of not having to meet the load that’s growing exponentially,” said Brown. “So … we are in a space right now where we can really get our policies in line. … But be ready, because in a year or so, it’s going to be a different day with the uptick of electricity demand and of course the electrification of everything that’s going on.”

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Granholm Attempts to Placate Coal State Senators

The Biden administration will not forget about fossil fuel industry workers as it transitions the U.S. to net-zero emissions by 2050, the president’s nominee to lead the Department of Energy, Jennifer Granholm, told the Senate Energy and Natural Resources Committee on Wednesday.

Republicans on the committee — and incoming committee Chair Joe Manchin (D-W.Va.) — sought assurance that Granholm would not seek to displace coal, oil and natural gas in the country’s energy mix. She did not shy away, pledging that the U.S. would continue to rely on fossil fuels even as it tries to reduce their greenhouse gas emissions.

Instead of speaking about the urgency of the climate crisis, as some Democrats on the committee did, she focused her remarks on the department’s role in funding research and development of technologies, such as carbon capture and sequestration, and often emphasized the “net” in “net zero.”

Granholm, who served as governor of Michigan from 2003 to 2011, also asserted that the transition would result in higher overall employment. She cited her experience of leading the state during the Great Recession, when General Motors and Chrysler filed for bankruptcy.

“Having been the governor of Michigan when the automotive industry was on its knees, I understand what it’s like to look in the eyes of men and women who have lost jobs through no fault of their own,” she said.

That industry, like energy, she noted, has historically been dependent on fossil fuels. She admitted that she and other Michigan officials had fought against tougher Corporate Average Fuel Economy standards “because we wanted to protect our industry.”

But the auto industry has begun transitioning to manufacturing electric vehicles, Granholm said. She frequently expressed her love for her Chevrolet Bolt.

The energy transition also offers an opportunity for the U.S. to import less, she said. In fossil fuel states, “there is an opportunity for us to specialize in the technologies that reduce carbon emissions; to make those technologies here; to put people to work here,” she told Manchin.

“We better believe that China is in this, and they are aggressively competing,” she said later. “States individually are bringing a knife to a gunfight, and without a federal partner to make sure we can get these jobs in America, then we will be losing globally.”

Granholm’s comments on protecting U.S. jobs echoed those of Biden when he issued several executive orders the same day. (See related story, Biden Signs Sweeping Climate Orders.)

‘A Hell of a Lot More Jobs’

Republicans on the committee, led by incoming ranking member John Barrasso (Wyo.), asked Granholm about Biden’s executive orders, such as a moratorium on new oil and gas drilling leases on federal lands and blocking the Keystone XL oil pipeline. (See Biden Begins Undoing Trump’s Legacy.) Republicans said these orders would cost thousands of jobs.

“We don’t want to see any jobs sacrificed,” Granholm told Barrasso. “This is why reducing GHG emissions is so important in the fossil fuel arena. The moratorium on public lands, I know, for those states that have those jobs in abundance, is something we’re going to have to work on together to ensure people remain employed.”

She noted that current leases to drill would not be affected by the moratorium. “So it gives us some time to be able to work on creating jobs. … [Biden] has put together a sort of SWAT team inside the federal government to focus on communities that have powered America.”

Sen. Bill Cassidy (R-La.) was skeptical.

“I think there is a question before the American people: Does the Biden administration actually care about their jobs?” he asked. “You had mentioned that the Biden team will have … a SWAT team to make sure that folks are employed. I’m thinking they have a SWAT team to take out their jobs.”

Cassidy noted that during his confirmation hearing, Pete Buttigieg, Biden’s nominee for transportation secretary, admitted that it would take years for clean energy jobs to become widely available. (Later that day, the Senate Commerce Committee advanced Buttigieg’s nomination to the floor, 21-3.)

“I totally get the concerns about jobs losses. Totally,” Granholm responded. She began to say that Biden had committed to create millions of jobs as part of his climate policies, but Cassidy cut her off.

“How quickly though? … If you’ve lost a job that is putting food on your table now, it’s cold comfort to know that years from now, perhaps in a different state, with a different training [that] you have, there will be another job available,” Cassidy said.

“I completely understand what you are saying,” she replied. “What I can tell you is … when we focused on incentives for job providers to locate in Michigan in clean energy, they came.” She noted that the department has unused funds for tax credits under Section 48c of the American Recovery and Reinvestment Act for clean energy manufacturing.

Sens. Bernie Sanders (Vt.) and Angus King (Maine), independent senators who caucus with Democrats, backed up Granholm on her focus on jobs.

“While there will be clearly, as we make the transformation, loss of some jobs, no question about it … 10 million jobs is a hell of a lot more jobs being created than being lost,” said Sanders, referring to one of Biden’s goals.

“The changes in employment patterns occasioned by the movement to a carbon-free economy are obvious, and they’re occurring,” King said. “What’s hard to calculate is the drastic changes to our economy if we don’t make this transition and the impacts all over the country in agriculture, in industry, in fisheries, in all of our coastal resources. … There’s an enormous cost on the other side that has to be part of this equation.”

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Biden Signs Sweeping Climate Orders

President Biden promised Wednesday to provide new economic opportunities to coal miners and power plant communities as he announced a “whole-of-government” approach to addressing climate change.

Joined by his two top climate advisers, former Secretary of State John Kerry and former EPA Administrator Gina McCarthy, the president signed a memorandum and two executive orders, calling for evidence-based policymaking, funding for disadvantaged communities and making climate change a central consideration in all federal government decisions.

“It’s not time for small measures. We need to be bold,” Biden said in remarks before the signing.

“So, let me be clear: [We are going] to revitalize the economies of coal, oil and gas and power plant communities. We’re never going to forget the men and women who dug the coal and built the nation,” Biden promised. “We’re going to do right by them [and] make sure they have opportunities to keep building the nation in their own communities and getting paid well for it.”

Biden signed a memorandum re-establishing scientific advisory committees, vowing that his administration will protect scientists from political interference and ensure their agencies make evidence-based decisions. Biden also signed an executive order re-establishing the President’s Council of Advisors on Science and Technology, and charged the Office of Science and Technology Policy (OSTP) with responsibility for ensuring scientific integrity across federal agencies.

At the Center of Foreign Policy and National Security

Another executive order says climate considerations will be “an essential element” of U.S. foreign policy and national security, with Kerry, named Biden’s special presidential envoy for climate, becoming a member of the National Security Council.

Biden will hold a Leaders’ Climate Summit on Earth Day, April 22, that will seek “to promote a significant increase in global ambition” to reduce emissions. Officials said the U.S. will determine its “nationally determined contribution” — or emission reduction target under the Paris Agreement — before the summit.

“The convening of this summit is essential to ensuring that 2021 is going to be the year that really makes up for the lost time of the last four years,” Kerry said in a press conference.

Kerry acknowledged the U.S.’ disputes with China over access to markets and intellectual property theft, vowing “those issues will never be traded for anything that has to do with climate. That’s not going to happen.”

The order also directs the director of national intelligence to prepare a National Intelligence Estimate on the security implications of climate change. “This is the first time a president has ever done that,” Kerry said.

Kerry acknowledged the cost of the $2 trillion climate plan Biden proposed during the campaign. “Yes, it’s a lot of money,” he said. “But you know what? It costs a lot more if you don’t do the things we need to do. There are countless economic analyses that show that it is now cheaper to deal with the crisis of climate than it is to ignore it. We spent $265 billion two years ago on three storms: Irma, Harvey and Maria. … So, we’re spending the money folks. We’re just not doing it smart. We’re not doing it in the way that would actually sustain us for the long term.”

‘Whole-of-government’ Approach

Biden also ordered the creation of an Office of Domestic Climate Policy in the White House, to be led by McCarthy, the first-ever national climate adviser. The office will serve as a clearing house for coordinating and implementing Biden’s domestic climate agenda.

The president also announced creation of the National Climate Task Force, a group of officials from 21 federal agencies and departments to take a “whole-of-government” approach to addressing climate change. Each federal agency will be required to develop a plan for increasing the resilience of their facilities and operations against climate change.

Biden also ordered federal agencies to purchase carbon-free electricity and zero-emission vehicles, saying it would “create good-paying, union jobs and stimulate clean energy industries.” Biden said the government’s support for EVs could generate 1 million new jobs.

The directive, which builds on Biden’s “Buy American” executive order on Monday, requires agencies to strictly enforce the prevailing wage and benefit guidelines of the Davis Bacon Act and other laws.

The secretary of the interior is required to “pause” new oil and natural gas leases on federal lands and waters “to the extent possible” and conduct a review of existing leasing and permitting practices related to fossil fuel development. The president said he would eliminate fossil fuel subsidies where possible under existing law and seek congressional approval for other cuts.

But he made clear he would not take a step some environmentalists have urged. “I know this always comes up,” Biden said in remarks before the signing. “We’re not going to ban fracking. We’ll protect jobs and grow jobs, including through stronger standards like controls [of] methane leaks and union workers willing to install the changes.”

Biden said his directives will create jobs in construction, manufacturing, engineering and skilled trades “by directing steps to ensure that every federal infrastructure investment reduces climate pollution and that steps are taken to accelerate clean energy and transmission projects under federal siting and permitting processes in an environmentally sustainable manner.”

He called for creation of a Civilian Climate Corps to employ people conserving and restoring public lands and waters, increasing reforestation and carbon sequestration in agriculture and protecting biodiversity. The Secretary of Agriculture was directed to collect input from farmers, ranchers, and other stakeholders on how to use federal programs to encourage adoption of climate-smart agricultural practices that produce carbon reductions and sequestrations.

Revitalize Energy Communities

Biden also established an Interagency Working Group on Coal and Power Plant Communities and Economic Revitalization, to be co-chaired by McCarthy and Brian Deese, director of the National Economic Council, to direct federal agencies to coordinate investments and other efforts to assist coal, oil and natural gas, and power plant communities.

The order also includes a “Justice40 Initiative,” requiring the chair of the Council on Environmental Quality, the director of the Office of Management and Budget and the national climate adviser to publish within 120 days “recommendations on how certain federal investments might be made toward a goal that 40% of the overall benefits flow to disadvantaged communities.”

The recommendations will focus on clean energy and energy efficiency; clean transit; affordable and sustainable housing; training and workforce development; the remediation of legacy pollution; and the development of clean water infrastructure.

“We have to make sure that in this transition, every agency in government is using every tool at their disposal to drive resources to those communities,” McCarthy said.

Kerry said displaced fossil fuel workers can find good jobs in the clean energy economy, such as installing solar panels and wind turbines.

“Seventy to seventy-five percent of all the electricity that’s come online in the U.S. in the last few years came from renewables. Coal plants have been closing over the last 20 years. What President Biden wants to do is make sure those folks have better choices; that they can be the people that make the solar panels. That we’re making them here at home.

“Unfortunately, workers have been fed a false narrative,” he continued. “They’ve been fed the notion that somehow dealing with climate is coming at their expense. No, it’s not. What’s happening to them is happening because of other market forces already taking place. What the financiers — the big banks, the asset managers, private investors, venture capitalists — are all discovering is there’s a lot of money to be made in the creation of these new jobs.”

Kerry’s comments echoed those that Biden’s nominee for secretary of energy, Jennifer Granholm, made during her confirmation hearing the same day. (See related story, Granholm Attempts to Placate Coal State Senators.)

Manchin Vows to Collect on Biden’s Promises

Sen. Joe Manchin (D-W.Va.), incoming chairman of the Senate Energy and Natural Resources Committee, issued a statement supporting the pause on new drilling leases on federal lands and waters. “Currently, 53% of onshore acres leased and 77% of offshore acres leased have no active production,” he said. “It is prudent to evaluate if taxpayers are receiving a fair return for the use of their resources. This executive order will not impact energy activity like drilling or permitting on existing leases.”

Manchin also reiterated his insistence that the nation seek innovation that allows it to address climate change without blacklisting fossil fuels.

“Instead of elimination, we must instead focus on utilizing all of our resources in the cleanest way possible. Today’s executive orders also commit the Biden administration to focus on reinvesting in communities that have seen the loss of traditional energy jobs, like many in West Virginia,” Manchin said.

“I intend to hold the administration to this while ensuring that the burden of any acceleration in already changing markets is not unduly placed on these communities that powered our nation to greatness. I stand ready to work with this administration to ensure West Virginia communities see these much needed investments.”

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MISO to Seek Extension on Order 2222 Plan

MISO will ask FERC for more time to plan the complicated process of opening its markets to distributed energy resource aggregators, RTO officials said Monday at a virtual workshop.

Staff said MISO must seek a six- to 12-month extension of the July 19 compliance filing date to in order create a sophisticated enough blueprint to comply with FERC’s Order 2222, which requires RTOs to establish rules allowing DERs to participate in organized wholesale markets on an aggregated basis.

MISO DER Program Director Kristin Swenson said an extension probably won’t affect MISO’s implementation date for compliance.

“But there’s a lot to work through before July, and we’re a little worried about that. … We’re not the only ISO looking to extend. Our brethren in the other ISOs … also think this is a lot,” Swenson said.

MISO Managing Assistant General Counsel Michael Kessler said some of the other RTOs would likely ask for similar extensions.

“The extension will allow for more time to have discussions like these,” he told stakeholders.

Swenson said adherence to the July filing date would likely provide staff and stakeholders with just one public forum in which to discuss the different aspects of the order.

She said getting transmission and distribution utilities and operators in the same discussions is crucial.

“We have mutual concerns about operating reliably,” Swenson said.

MISO may have to wait as long as two months for FERC’s response and will continue to operate as if the July deadline is a foregone conclusion, Swenson said. She said the RTO will begin revealing “segments” of a conceptual design in March.

“There’s a tremendous amount of operating variability” among MISO distribution utilities, Swenson said. She predicted all parties involved — MISO, utilities, aggregators and regulators — will face challenges in delegating the roles and responsibilities that will enable DERs to operate reliably in the organized wholesale market.

“That’s why we think this will take more than the next five months to answer,” she said.

Kessler said codifying Order 2222 in MISO’s nearly 7,000-page tariff is no small order.

“Of those 7,000 pages, we’ll be going through the relevant provisions that will be affected by Order 2222 and adding provisions to allow for the participation of these resources,” he explained.

The Grid Post-Order 2222: A “Cool” Time

Enerdynamics’ Bob Shively, tapped by MISO for a DER lecture Jan. 26, said he envisions a “hybrid grid” where large, centralized power plants deliver alongside scattered and aggregated resources.

“Most of these DERs have the technical capability of providing most, if not all, of the technical capability that MISO requires of them,” Shively said. “Now with the Biden administration, there’s more interest. FERC is clearly now more interested in creating a level playing field for DERs to compete with centralized power plants.”

Critics have claimed Order 2222 is the first example of the commission leading policy before the technology is adopted, Shively said. He said by FERC definition, several technologies can be combined into a single DER aggregation.

“That’s something new, possibly getting storage, generation and demand response into one aggregation,” Shively said, adding that nearly all organized markets started on Order 2222 “to some extent” when they adapted their markets to accommodate demand response participation.

Shively said while DER aggregations will likely bring more price volatility into wholesale markets, they’ll also lower costs overall because most DERs are marginal or zero-cost resources.

A more flexible customer base will be key to managing a more decentralized resource base, and time-of-use customer programs can provide financial incentives to manage demand, he said. He also predicted most vehicle owners would be driving electric vehicles in about a decade.

“There’s a lot of potential interest in having EV charging happen at the office in the middle of the day,” Shively said.

Information exchanges to achieve visibility between distribution and transmission operators remain an impediment, he said.

“Right now, we don’t have a standardized way of collecting DER amounts and locations,” he said. “There’s just a level of cooperation that wasn’t required before that’s going to be a requirement.” He added that MISO, aggregators, DER owners and distribution utilities will have to figure out who needs contracts.

The RTO also must work out how to price DERs in the same aggregation when they span multiple pricing nodes, he said.

Shively said MISO, other RTOs and distribution utilities will transition from “grids to deliver electricity to networks that provide energy services.” He said RTOs, utilities, regulators and energy companies are at a juncture where they can determine the future of the electricity generation, delivery and use.

While it can be frustrating to get DER market mechanisms in place, Shively said, it’s also an exciting time to be in the industry.

“I know people who say, ‘I can’t retire now, there’s too much to do.’ It’s such a cool time,” he said.

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SERC Ranks Cybersecurity as Top Risk

Cybersecurity ranks as the top reliability risk in the Southeast, followed by extreme weather events and the integration of variable energy resources, SERC said Tuesday during a quarterly open forum, where it reviewed its 2020 Risk Report.

“One thing consistently being number one is cybersecurity threats resulting from exploitation — both internal and external players,” said Gaurav Karandikar, SERC manager for reliability assessment, performance analysis and technical services.

The report focuses on risk management and communication, prioritizing risks based on the probability of occurrence and severity of impact to the region.

“The report is central to everything and anything we do here at SERC,” Karandikar said. “Prioritizing risk enables us to mobilize and deploy our resources to address those risks with the most important impact.”

Borrowing from NERC’s 2019 ERO Reliability Risk Priorities Report, SERC now defines risks in four high-level categories: grid transformation, extreme natural events, security vulnerabilities and critical infrastructure interdependency.

“Gathering that information at a departmental level and a regional level is so important to understanding the ambient risk of our entities,” Karandikar said. “And the risks that are emerging are being reduced through our efforts. We want to make sure that we are spending the resource at the right place.”

Entity Assistance Goes Virtual

Bill Peterson, SERC manager for outreach and training, reviewed the assistance given to entities over the past year, mostly virtual because of the pandemic, and the lessons learned, distinguishing between voluntary outreach programs and mandatory compliance activities.

“I’m happy to share that we were very busy last year, just had to change a little bit how we went about doing things,” Peterson said.

The team completed nearly 50 requests for assistance, comparable to 2019, but made no on-site visits, down from 13 the previous year.

“We had a lot of questions on the pandemic and impacts that has on SERC programs,” he said. “We spent quite a bit of time with entities working on the challenges and finding solutions, and in particular supply chain was a big focus area for many of us.”

Lessons learned in supply chain assistance included the need to use asset lists to identify procurements and vendors, use patching sources to identify software vendors and consider requiring vendors to provide a detailed bill of materials, he said.

Industry Experts, Align Update

The pandemic reduced the use of volunteer consultants from registered entities, but SERC nonetheless required the services of an Industry Subject Matter Expert (ISME), according to a report by Todd Curl, SERC senior manager for compliance monitoring.

“Occasionally we have an audit where the manager feels we have a little bit of a technical gap here and may recommend the services of an ISME,” Curl said. “Once we vet folks for participation in the program, we have a good resource pool.”

SERC selects volunteer ISMEs based on their technical expertise in operations, planning and cybersecurity, Curl said, encouraging anyone interested in applying to write to ISME@serc1.org.

Curl also presented an update on the rollout of the new Align compliance monitoring and enforcement program tool, which is scheduled to go live May 24.

“With the implementation of Align, all the regional entities in the ERO will be using a common system and consistent processes for managing compliance monitoring and enforcement program activities with their entities,” Curl said. The Align rollout consists of three releases, with full implementation by the end of this year.

Learning from Remote Auditing

The pandemic required audits be done remotely, compounding the challenges of evaluating compliance but also providing valuable lessons for the future, according to a report on remote auditing by SERC and Reliability First (RF).

Stephen Brown, SERC manager for critical infrastructure protection (CIP) monitoring, said most registered entities readily agreed to move to remote audits last March, a willingness he attributed to the good relationships and strong communication between SERC and its members.

Performance audits are stressful, but their scope is consistent with the registered entity’s risk to the bulk electric system, Brown said.

“This was a strong effort and something that came out of 2020 that I really want to take bits and pieces from … and move them into 2021 and beyond,” Brown said.

Zack Brinkman, RF manager for CIP monitoring, agreed; “If you would have said prior to 2020 that we could audit six CIPs during an offsite review, you would have gotten some interesting looks, but the regions brainstormed new ideas, [and] we were able to come up with a method to do so.”

RF and SERC both adopted an approach that was being used in another region, which leveraged a template, allowing them to collect evidence in one shot, minimizing the amount of time needed for each location, Brinkman said.

Winter Weather Readiness

Balancing authorities and market operators should consider bringing units to minimum load prior to anticipated severe cold weather, said SERC Program Manager for Event Analysis, Hassan Hamdar, who presented on the NERC reliability guideline for generating unit winter weather readiness.

NERC reliability guidelines are intended to share good practices to improve reliability of the bulk power system but do not represent binding standards. And while their use is strictly voluntary, entities are highly encouraged to follow them, Hamdar said.

“The purpose of this guideline is really to help share information on issues related to cold weather where we’re not used to seeing cold weather,” he said. “It’s really prolonged cold weather that really impacts. The driver for this guideline was the 2011 cold weather event that occurred in Texas, though that’s not the only place it’s happened, and that wasn’t the first time it happened.”

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Knowledge Gaps Seen as Barrier to Vehicle Electrification

In the race to decarbonize the transportation sector, focusing on fleet vehicles, which account for only 3% of registered vehicles in the country, might seem insignificant. But a report by the Rocky Mountain Institute (RMI) says that a successful transition of fleets will influence the rest of the transportation sector.

“Large fleets drive scale, which results in reduced costs of vehicle technology and infrastructure,” RMI said. “And fleets have the market influence to help drive costly inefficiencies out of the system, resulting, for example, in streamlined permitting processes and prioritized utility interconnect processes.”

The think tank says more than 20% of all U.S. vehicles need to be electric by 2030 to limit climate change to 1.5 degrees Celsius, the threshold set in the Paris Agreement on climate change.

Progress in greening U.S. fleet cars is currently hindered by two significant knowledge gaps, according to the report, “Steep Climb Ahead: How fleet managers can prepare for the coming wave of electrified vehicles.”

While fleet managers know how to procure and maintain vehicles, they have little experience in building and maintaining the charging infrastructure for electric vehicles, RMI said. In addition, the organizations running fleets are not versed in utility rate structures.

Driving Without a Map

The report, which is based on a survey of managers responsible for large fleets, found that 81% of organizations have begun electrifying vehicles but that only about half of those have set explicit goals for transitioning their fleets. The report also said many organizations have not been planning for the charging infrastructure required to support their growing green fleets. In fact, investment by organizations has been upside down, going first to vehicles and then to charging infrastructure, where investment in infrastructure should be the priority. A lack of charging stations could act as a cap on EV adoption, the report said.

“Although many fleets have already implemented pilot programs — usually consisting of a few EVs and low-powered chargers, acquired at modest expense — electrifying a fleet at scale involves much more than just adding more EVs and chargers incrementally,” RMI said. “For many organizations, it will mean restructuring their internal business processes, including procurement, accounting, long-term capital project planning, fiscal budgeting, operations and more” to understand their return on investment and total cost of ownership.

The report says the charging infrastructure necessary to serve truck stops and fleet yards with medium- and heavy-duty trucks can take years to plan and build. It says some fleet managers may be surprised to learn that use of public chargers or Level 2 chargers (7.2 kW) will not suffice and that they will have to install more expensive direct current fast charge (DCFC) units (150 kW).

Of the total number of charge stations in the U.S., DCFC accounts for about 15%, according to the consulting firm EVAdoption. The RMI report said fleet managers planning to expand EV procurement need to begin talks with their utility “at least three years before they expect to actually need the power.”

“We strongly suspect that many fleet managers are in for some unpleasant shocks when they receive the first utility bills for their first set of DCFC,” the report added.

As a result, fleet operators will need “a much more extensive relationship with their local utilities,” RMI said. “And it will mean much more proactive involvement with city and county officials, including local building and planning authorities.”

The report recommends fleets consider “charging as a service” to navigate the complexity of managing vehicle charging around their duty cycles.

Wall Street Takes Notice

The growing infrastructure needs of EVs are attracting attention on Wall Street. Among those offering charging as a service is ChargePoint, which plans to go public next month. EVgo, which has more than 800 fast charging locations in 34 states, also is planning a public offering. And Royal Dutch Shell announced Monday that it is acquiring Ubitricity, the U.K.’s largest EV charging network, in a bid to diversify from fossil fuels.

Jonathan Levy, chief commercial officer for fast EV charger provider EVgo, told RTO Insider that the company is working with fleet managers “to inform their best path to convert their vehicles to EVs.”

Charging solutions will vary “depending on the particular use case,” Levy said.

A Solution Set

RMI’s findings of a knowledge gap among fleet managers are also echoed in a report prepared by the Center for Transportation and the Environment (CTE), released this month by the Federal Transit Administration (FTA).

The report summarizes the discussions of FTA’s Transit Vehicle Innovation Deployment Centers (TVIDC) Advisory Panel on the challenges of electrifying municipal bus fleets. Prior to the adoption of battery-electric buses (BEB), few transit authorities had experience working with utilities as suppliers of bus fuel, the report says. Similarly, utilities are still early in the learning curve of BEB technology and its infrastructure and power requirements.

“Both industries still lack answers for how best to affordably and effectively deploy large-scale electric charging infrastructure at existing transit facilities,” the report said. The learning curve issues were also the subject of discussions at CTE’s Zero Emission Bus Conference last fall. (See Takeaways from the Zero Emission Bus Conference.)

To alleviate costly surprises for fleet managers, the TVIDC panel suggested that an FTA-sponsored, cross-industry working group develop frameworks that help fleet owners and utilities with common issues, such as infrastructure scaling and installation; liability and equipment testing; and certification.

The panel also suggested that making a planning guidebook available to fleet managers could ensure they understand utility operations, power planning and rate-setting issues.

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NERC Opens Comments on CIP Changes

The standards drafting team (SDT) for NERC’s Project 2016-02 is accepting comments through 8 p.m. March 22 on proposed changes to the ERO’s Critical Infrastructure Protection (CIP) reliability standards that are intended to “incorporate virtualization and future technologies.”

Ballot pools are being formed through Feb. 19, and initial ballots and nonbinding polls will be conducted March 12 to 22. NERC is conducting a separate ballot and poll for each of the affected standards, so entities must join the pools for all of the standards on which they wish to comment.

Broad Scope for Proposed Updates

NERC’s Standards Committee approved the posting at its meeting last week. (See NERC Seeks Faster Pace for Standards Postings.) The standard 45-day comment period was extended to 60 days because of the project’s scope, with proposed revisions to 11 standards:

      • CIP-002-7 — Bulk electric system cyber system categorization
      • CIP-003-9 — Security management controls
      • CIP-004-7 — Personnel and training
      • CIP-005-8 — BES cyber system logical isolation
      • CIP-006-7 — Physical security of BES cyber systems
      • CIP-007-7 — Systems security management
      • CIP-008-7 — Incident reporting and response planning
      • CIP-009-7 — Recovery plans for BES cyber systems
      • CIP-010-5 — Configuration change management and vulnerability assessments
      • CIP-011-3 — Information protection
      • CIP-013-3 — Supply chain risk management

At last week’s meeting, NERC Manager of Standards Development Soo Jin Kim explained that the project had been “lying in wait for a little while” because of active comment periods involving some of the same standards; as a result of this delay, the SDT had more time than most teams to add more proposed changes to the inquiry.

“What we have before you today is work that has culminated after many months; the team has waited, and now they will put forth all of their modifications in this package before you today,” Kim said.

In addition to general commentary on proposed standards, the SDT posed 18 questions for industry respondents relating to specific changes. Significant updates include:

      • modifications to CIP-002 and CIP-005 expanding their scope to encompass virtual machines;
      • requirements regarding the types of software to be used when conducting vulnerability assessments before connecting physical or virtual cyber assets;
      • mandatory confidentiality and integrity protections for data passing between multiple physical security perimeters;
      • allowing cryptographic erasure in scenarios where BES cyber information “cannot be mapped to particular disks in virtualized storage”; and
      • applying CIP exceptional circumstances, which allow utilities to temporarily waive certain CIP obligations, to additional requirements in CIP-004, CIP-006 and CIP-010.

The team also put forward for industry comment a number of new, modified or retired definitions for terms in NERC’s glossary, along with the implementation plan for the revised CIP standards and definitions. Under that plan, the standards and definitions will take effect on the first day of the first calendar quarter that is 24 months after their approval by FERC, unless an entity elects to implement them earlier. The SDT asked respondents to suggest an alternate effective date if preferred, along with an explanation of the work and time requirements to justify the change.