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December 22, 2025

CAISO Issues Final Report on August Blackouts

CAISO and its sister state agencies released a final, more detailed analysis Wednesday of the mid-August blackouts and steps they are taking to prevent capacity shortfalls this summer and beyond.

“We recognize our shared responsibility for the power outages many Californians unnecessarily endured,” stated a cover letter to Gov. Gavin Newsom signed jointly by the heads of CAISO, the California Public Utilities Commission and the state’s Energy Commission. “The findings of the final analysis underscore this shared responsibility and give greater definition to actions that can be taken to avoid or minimize the impacts to those we serve.”

CAISO Blackouts
Blackouts on Aug.14-15 occurred around 6:30 p.m. as solar ramped down. | CAISO

Requested by Newsom, the report incorporates data that was not yet available during the preparation of a preliminary root-cause analysis issued in October. (See CAISO Says Constrained Tx Contributed to Blackouts.)

The final report mainly confirms the preliminary conclusion that the rolling blackouts CAISO ordered Aug. 14-15 resulted from a combination of severe heat across the West, inadequate resource planning and market practices that undermined procurement. But it elaborates on those findings with more specific evidence and recommendations gleaned from months of investigation.

“This Final Root Cause Analysis provides important insights and lessons learned about the factors that contributed to the rotating power outages of last summer,” CAISO CEO Elliot Mainzer said in a statement. “As we prepare for summer 2021 and beyond, I look forward to working closely with the CPUC, CEC, policymakers and regional stakeholders to bring our planning, procurement and operational practices together into a modernized and well-integrated resource adequacy framework for California.”

CAISO previously said that import bids in the day-ahead market were 40 to 50% higher during the energy emergencies of August than typical resource adequacy requirements at that time of year, but transmission constraints limited the transfers into CAISO’s footprint. A major transmission line from the Pacific Northwest had been derated because of the weather, the preliminary analysis reported.

The final analysis newly reported that the line in question had experienced a forced outage because of a storm in May 2020 that damaged the line and derated the California-Oregon Intertie (COI) into August.

“The derate reduced the CAISO’s transfer capability by nearly 650 MW and caused congestion on usual import transmission paths across the COI and Nevada-Oregon Border,” the final report said. “In other words, more energy was available in the north than could be physically delivered, and the total import level was less than the amount the CAISO typically receives.”

One of CAISO’s current efforts — part of its Resource Adequacy Enhancements stakeholder initiative — is a controversial proposal to contract for the highest level of firm transmission into CAISO from the Northwest, guaranteeing delivery of essential hydropower resources. (See CAISO Seeks ‘Firm’ Tx for Resource Adequacy.)

Another RA effort involves more accurately accounting for the capacity of intermittent resources such as wind and solar, which can be unpredictable.

Updated figures in the final report showed combined RA values for solar and wind fell by 1,300 MW Aug. 14-15. Solar generation was reduced because of high cloud cover and smoke from wildfires raging at the time. Wind generation dropped without warning by 1,200 MW on Aug. 15 caused by tropical storm influences from the south.

When wind plummeted during the so-called net peak, as solar waned and demand remained high in the early evening, CAISO was unable to maintain its safety reserves to prevent larger grid failure.

The report recommends that the state update it estimations of wind and solar capacity.

“The CPUC has improved the methods for estimating the reliability megawatt value of solar and wind over the years, but the reliability value of intermittent resources is still over-estimated during the net peak hour,” it said. “Improvements to the RA program should account for time-dependent capabilities of intermittent resources.”

CAISO Blackouts
| Ready.gov

More RA, Batteries

The report noted other efforts underway to avoid future shortfalls. They include an emergency reliability rulemaking by the CPUC to procure additional resources to meet demand this summer.

“Through this proceeding, the CPUC has already directed the state’s three large investor-owned utilities to seek contracts for additional supply-side capacity and has requested proposals for additional demand-side resources that can be available during the net demand peak period (i.e., the hours past the gross peak when solar production is very low or zero) for summer 2021 and summer 2022,” the report said.

CAISO is performing an analysis to increase the CPUC’s RA procurement targets.

“Based on the analysis to date, CAISO recommends that the targets apply to both the gross peak and the critical hour of the net demand peak period during the months of June through October 2021,” it said.

The ISO is expediting a stakeholder process to consider market rule changes by June to “ensure the CAISO’s market mechanisms accurately reflect the actual balance of supply and demand during stressed operating conditions.” (See Summer Readiness Sought by CAISO, CPUC.)

CAISO is also working to integrate hundreds of megawatts of battery storage into its grid by summer to store excess solar and wind power for use during the evening net peak. The CPUC said it is trying to remove regulatory obstacles to battery and generation resources coming online by this summer.

“The acceleration of climate change demands we enhance our planning efforts and market practices at a faster pace and with broader anticipation for what is possible,” CPUC President Marybel Batjer said in a statement. “It is our top priority to ensure we have the demand- and supply-side resources needed to maintain reliability, and this [final root-cause] analysis demonstrates how we will do it and continue to decarbonize the grid.”

NY Awards 2.5-GW Offshore Deal to Equinor

New York on Wednesday announced that it is awarding 2,490 MW in offshore wind contracts to Equinor Wind US, the largest such procurement ever in the U.S.

Equinor and its partner, BP, will develop two separate projects: an additional 1,260 MW for the companies’ Empire Wind in the New York Bight, and the 1,230-MW Beacon Wind, to be located more than 60 miles east of Montauk. State officials had already selected the initial 816-MW phase for Empire Wind, and Beacon Wind could add up to 1,170 MW in the future.

“These projects will deliver homegrown, renewable electricity to New York and play a major role in the state’s ambitions of becoming a global offshore wind hub,” Equinor CEO Anders Opedal said in a statement.

The new contracts bring the state’s total OSW procurement to about 4.4 GW, nearly half the 9 GW targeted by 2035. Along with Empire Wind 1, New York in 2018 selected the 816-MW Sunrise Wind project and the 130-MW South Fork Wind Farm.

Equinor
Empire Wind is located 15 to 30 miles southeast of Long Island and spans 80,000 acres, with water depths between 65 and 131 feet. The lease was acquired in 2017 and is being developed in two phases (Empire Wind 1 and 2) with a total installed capacity of more than 2 GW (816 and 1,260 MW). | BOEM

The terms for the latest deals have not been announced, but officials estimate the projects will bring $8.9 billion in investment and create more than 5,200 jobs, an economic stimulus sweetened by commitments from companies to manufacture wind turbine components in New York. For example, the country’s first OSW tower-manufacturing plant will be built at the Port of Albany; a turbine-staging facility and operations and maintenance hub will be set up at the South Brooklyn Marine Terminal; and other support activities will take place at the ports of Coeymans, Jefferson and Montauk Harbor in Long Island.

Other Projects

New York also made several other announcements related to renewable and clean energy as part of the third segment of Gov. Andrew Cuomo’s State of the State address, which began Monday. (See Cuomo Outlines Green Path for New York in 2021.)

The state issued a solicitation for transmission projects to bring renewable energy from upstate and Canada to New York City as part of Tier 4 of its Clean Energy Standard. The state is hoping these transmission “arteries” will feed a 250-mile, $2 billion green “superhighway” project

“Supercharging the new transmission superhighway will be vital to completing New York’s nation-leading green economic recovery and accelerating renewable energy development programs,” it said.

Equinor
New York Gov. Andrew Cuomo delivers the energy portion of his State of the State address on Jan. 13. | New York DPS

Transmission congestion around New York City could increase after the first 6,000 MW of offshore wind is interconnected without coordinated planning, OSW Growth to Test New York’s Transmission Grid.)

In addition, the state announced it will this year contract for 23 solar farms and one hydroelectric facility worth more than 2,200 MW.

It is also investing $20 million in a new OSW Training Institute based at the State University of New York at Stony Brook and Farmingdale State College to train at least 2,500 people for jobs in renewable energy. New York State Energy Research and Development Authority and SUNY issued the first solicitation for advanced technology training partners to train the first group of workers beginning this summer.

Anne Reynolds, executive director of the Alliance for Clean Energy New York, lauded the news but said, “There is some unfinished business in helping renewables get built, and that is providing some guidance to towns on how to properly value and tax wind and solar projects. ACE NY is calling on the governor and legislature to devise a pathway to standardized taxation for renewable energy.”

“The governor’s focus on transmission upgrades will ensure that the clean power generated by offshore wind projects is brought to the grid in an efficient and cost-effective manner,” Joseph Martens, director of the New York Offshore Wind Alliance, said in a statement.

MISO, SPP Regulators Call for Pancaking Fix, Smaller Projects

Regulators hailing from SPP’s and MISO’s footprint would like to see the grid operators improve seams relations by resolving rate pancaking and adding a smaller interregional project category.

The MISO-SPP Seams Liaison Committee (SLC), comprised of regulators from the Organization of MISO States (OMS) and SPP’s Regional State Committee (RSC), agreed this week that the RTOs would best be served by addressing multiple transmission charges at their seam and creating a class of smaller cross-border projects similar to the Targeted Market Efficiency Projects (TMEPs) used by MISO and PJM.

The two items top the regulators’ draft list of seams recommendations. The regulators also designated current interconnection queue processes and interregional transmission planning efforts as medium priority.

The SLC relegated market-to-market improvements, developing an interface pricing process, and coordinated transaction scheduling to low priority status.

Texas Public Utility Commission Chair DeAnn Walker will share the draft list of recommendations with the RSC when it next meets on Jan. 25. She cautioned her fellow regulators that the draft document “could come out of the RSC looking much different,” as the committee has not been as involved as the OMS the last few months.

“I would like to get more concrete direction from the RSC as a whole,” she said during the committee’s call on Tuesday. “Maybe [RSC’s members] will provide a little bit more insight and clarity on this.”

“I would prefer Chairman Walker go to our RSC first,” RSC’s newly elected president Kristie Fiegen said. “We haven’t been able to discuss anything because we haven’t had a publicly noticed meeting [lately].”

Walker acknowledged that MISO and SPP are already working to address many of the topics, giving partial credit to the SLC. “We’ve done a lot in getting MISO and SPP to work together where there was probably a little bit of a roadblock before,” she said.

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

Missouri Public Service Commissioner Ryan Silvey said that while the OMS and RSC have agreed on the majority of the recommendations, differences on issue prioritization are because the RTOs already have plans in place to make improvements.

Walker said tackling transmission rate pancaking between MISO and SPP is the most “controversial” recommendation because it would require significant member agreement and stakeholder votes to come to a solution.

“I think there are a lot of members who would like to see this move forward, but there are just as many who wouldn’t,” she said. A pancaking solution could potentially result in “years of drawn-out litigation,” she said, noting multiple Texas utilities have litigious histories.

“I don’t see them being docile,” Walker warned.

The SLC may put together a working group to address rate pancaking between MISO and SPP.

“What I hope this will turn into is a negotiation that turns into an agreement first with the [transmission owners] and spreads to other members,” Arkansas Public Service Commission Chairman Ted Thomas said late last year.

OMS and RSC also recommended the grid operators use the TMEPs study category, which MISO and PJM use to identify smaller transmission projects that ease historical congestion along the seams.

Last year, regulators appeared split over whether MISO and SPP should embark on their own TMEP process. Some MISO South regulators have maintained that the seam isn’t mature enough to benefit from congestion-relieving TMEPs.

Others said a similar process — not an exact replica — could work.

“I don’t know that we need to get tangled up in exactly the same specific study process, but that we have one that accomplishes the same study objectives,” North Dakota Commissioner Julie Fedorchak said last year.

MISO and SPP have never approved a major interregional transmission project. Some in the MISO stakeholder community have suggested TMEPs as a route to alleviate some cross-border congestion.

Having finalized its recommendations, the committee may now transition to a monitoring role on MISO-SPP seams issues and hold less frequent meetings. Commissioners noted that the OMS is advisory in nature while the RSC has specific oversight bylaws. Some said the difference could limit how the committee issues guidance going forward.

ISO-NE, NEPOOL to Kick off State Technical Forums

Last fall, governors from five of the six New England states — Connecticut, Maine, Massachusetts, Rhode Island and Vermont — jointly released a pointed statement that said ISO-NE was frustrating regional and state-specific efforts to reduce economy-wide greenhouse gas emissions. It also called for reforms to the RTO’s market designs, transmission planning and governance.

An eight-page critique circulated by the New England States Committee on Electricity (NESCOE) soon thereafter detailed and expanded on the governors’ call for reformative action. The vision statement also referred to a series of online public technical conferences to convene, which would seek “presentations and proposals … and solicit comments and dialogue with all interested stakeholders.”

The first of those forums is Wednesday and will focus on wholesale market design. Two of the presentations from “interested stakeholders” are representatives from ISO-NE and NEPOOL, indicating a collaborative process from the start.

Interested Parties

NEPOOL Participants Committee Chair David Cavanaugh signaled an early interest in participating in the technical forums in December.

ISO-NE NEPOOL

David Cavanaugh, NEPOOL | © RTO Insider

At a meeting of the ISO-NE Consumer Liaison Group, Cavanaugh said NEPOOL has worked with the RTO and NESCOE through the stakeholder process on the Future Grid Initiative, which includes a reliability study and potential pathways, the latter of which “looks to identify a framework that may facilitate the entry of state policy resources.” (See Consumer Panel Discusses ISO-NE’ Visions of the Future’.)

Cavanaugh, senior vice president of regulatory and market affairs at Energy New England, said New England has been struggling “with the tension of integrating state policy resources.”

“If 2021 was to have a success statement, it would be to find the appropriate pathways that balance investment, as well as state policy resources and achieving state goals, because you have to have a balance,” Cavanaugh said. “You still want to have the signals to draw merchant investment in the region because you need it, but you also need the ability to represent and respect state policy, so if ’21 could deliver anything, it’d be identifying a pathway that’s successful in achieving that goal.”

Flash forward, and Cavanaugh will be charged with educating the public on the NEPOOL stakeholder process and its sectors, in addition to a high-level overview of existing initiatives, discussion of the Future Grid Initiative and answering audience questions.

“Given NEPOOL’s critical role in the region as the FERC-approved stakeholder forum for consideration of any and all changes to the design and operation of New England’s wholesale electricity markets, it is important for NEPOOL to engage in discussions that may help to inform ongoing or future NEPOOL stakeholder processes,” Cavanaugh told RTO Insider.

Cavanaugh noted the Future Grid Initiative will “explore and evaluate potential market frameworks that could be pursued to help support New England’s clean energy transition.”

“These processes provide the forum for NEPOOL participants, state officials and representatives, and ISO-NE to find common understanding among a diverse set of interests on potential pathways forward, and to support the region’s efforts to find consensus, where possible,” Cavanaugh said. “I am hopeful that the states’ technical conferences will help to complement and further collaborative efforts around the NEPOOL stakeholder table.”

ISO-NE headquarters in Holyoke, Mass. | ISO-NE

Cavanaugh, a 35-year energy industry veteran who has also worked at ISO-NE, NRG Energy and Eversource Energy, said the technical forums “present an opportunity for regional stakeholders to better understand the individual and/or collective views of the New England states on the issues identified” by the governors and NESCOE.

For ISO-NE, Eric Johnson, the RTO’s director of external affairs, will provide an organizational overview, discuss resource adequacy and talk through the development and administration of competitive electricity markets.

In an email to RTO Insider, Janine Saunders, corporate communications manager for the RTO, said that building “a cleaner electricity system is an important step in confronting climate change and is a vision we share with our state leaders.”

“Collaboration with our New England stakeholders has already resulted in one of the cleanest, most efficient fleets of power generating resources in the U.S.,” Saunders added. “We look forward to continuing our work with the states and others to keep building on that solid foundation.”

State Thoughts

Katie Dykes, commissioner of Connecticut’s Department of Energy and Environmental Protection, said one of the goals in launching the technical forums is to ensure that anyone who has an interest and wants information on “the future of our shared regional electric grid can access it and be part of the conversation.” Public forums bring “new people into the discussion,” she said.

ISO-NE NEPOOL

Connecticut DEEP Commissioner Katie Dykes | © RTO Insider

Dykes has not been shy about criticizing ISO-NE, especially on carbon pricing, but she recognizes that before any potential reforms, it is important to understand the perspectives of the RTO and NEPOOL and the shared history of the organizations.

“Institutions that have facilitated regional cooperation or operation of the grid and investment in the grid have evolved over time,” Dykes said. “It’s important for us to really start with that history and that understanding of how the grid, and the governance processes in organizations associated with it, have evolved to be able to set our intention of how we want our markets, transmission and the governance to be structured in the future.”

All parties involved “have a lot of work to do,” according to Dykes. The forums present an opportunity for states to provide primers on the laws, policies and perspectives that drive energy policy; modeling related to carbon-reduction goals; and mandates that are “at the forefront of why we feel that a real transformation of our electric supply in our grid is necessary.” It is also a chance to highlight a commitment to regional cooperation and “utilizing competitive markets to achieve the most affordable, clean electric supply that we can,” she said.

“I think it’s important for us to start off with an understanding of how our regional grid has evolved … in order to take the conversation further and look at how we can harness competitive markets and regional cooperation to achieve a transformation or rapid decarbonization of our electric grid,” Dykes said.

On Jan. 25, there will be another forum on the design of wholesale markets. Additional forums on transmission planning and governance reform of ISO-NE are slated for February. Following the forums, state representatives will report to their respective governors any findings and recommendations for action.

NOI Responses Describe Supply Chain Challenges

Industry participants support federal efforts to limit acquisition of foreign-manufactured hardware but warn that rooting it out of existing systems “presents significant challenges,” according to responses to FERC’s inquiry on reliability risks from such bulk electric system equipment (RM20-19).

FERC issued its Notice of Inquiry in September in response to President Trump’s executive order last May declaring a national emergency regarding foreign threats to the BES and restricting purchases of BES equipment from suppliers suspected of connections with “foreign adversaries,” which the Department of Energy later clarified to include China, Russia, Iran, Cuba, North Korea and Venezuela. (See FERC Opens Supply Chain Cyber Risk Inquiry.)

The commission sought comments from industry on:

  • the extent of the use in BES operations of equipment and services provided by entities identified as risks to national security;
  • the potential risks to BES reliability and security posed by such equipment and services;
  • whether NERC’s Critical Infrastructure Protection (CIP) standards adequately mitigate those risks;
  • what mandatory actions by the commission might mitigate those risks;
  • strategies that entities have implemented or plan to implement to address such risks, in addition to compliance with CIP standards; and
  • other methods the commission may employ to address this matter.

Searching for Threats Poses Problems

On the extent of the grid’s exposure to equipment from foreign adversaries, many respondents asserted that utilities are proactive in keeping their infrastructure clean of potentially dangerous hardware. Bonneville Power Administration (BPA) said that identifying equipment branded by a specific company such as Huawei or ZTE is “relatively straightforward” and that it had already verified its systems are free of devices from both companies and others named in the NOI.

BES security
ZTE headquarters in Shenzhen, China

NERC and the regional entities echoed BPA’s assessment, observing that their data indicated “minimal exposure” to the manufacturers in the BES, and the Electric Power Supply Association — which represents independent power producers and marketers — reported that its members “have extensive procurement protocols in place.”

But finding equipment from ZTE, Huawei and other suspect manufacturers is not as simple as it might at first seem because a piece of hardware made by another company may contain components from one of those firms; for example, network interface controllers (NIC) made by Huawei and ZTE are found in many devices made by other companies.

NERC and FERC acknowledged this in a joint white paper last year presenting techniques utilities can use to identify the manufacturer of NICs on their systems, though they acknowledged it is not totally foolproof. (See FERC, NERC Offer Cyber Supply Chain Guidance.) But even if these problematic components are discovered, removing and replacing them is still a major challenge; BPA said that it has “thousands of [NICs] in service … and physical inspection would require an enormous amount of manpower.”

CIP Standards Seen as Effective

Sentiments toward the CIP standards were generally positive, with the North American Generator Forum saying the standards “provide a sufficient risk-based, defense-in-depth approach to cybersecurity of the BES.” The Edison Electric Institute concurred, praising CIP-013-1 (Supply chain risk management) in particular for not requiring “any specific controls or mandate[ing] one-side-fits-all requirements … [instead taking] a flexible approach to allow responsible entities to establish” their own frameworks for assessing cybersecurity risk.

Exelon agreed that CIP-013-1 provided “a framework for addressing the risks” posed by foreign-connected hardware providers and further asserted that “the nation’s electric utilities have gone above and beyond the requirements of the standard” by jointly developing a risk assessment tool for the entire industry. This ensures that utilities can evaluate vendors’ cybersecurity practices efficiently, while giving vendors a standardized set of requirements to respond to.

Some respondents shared this positive assessment but felt the CIP standards as a whole could go further. The DOE noted that the issue of hardware vulnerabilities “goes beyond the narrow confines of” ZTE, Huawei and the other companies named in the NOI. It urged the commission to order an investigation of the CIP standards by NERC that would “identify any gaps in application.”

The Bureau of Reclamation said the current CIP standards “do not adequately mitigate the identified risks,” but recommended against modifying them. Instead, the bureau suggested that the commission order the National Institute of Standards and Technology’s (NIST) Cyber Security Framework be applied to all BES cyber systems.

“The focus should not be on what is wrong with the CIP standards or how to better align them with NIST, but what is right with the NIST standards and how a convergence on a single set of standards would improve BES resilience and security,” the bureau said.

NERC and the REs cautioned against drawing conclusions about the efficacy of the CIP standards, noting that standards relating to supply chain risk management only went into effect on Oct. 1, 2020 and that the ERO Enterprise “has only just begun assessing” their performance. The organizations requested that FERC wait until NERC has completed the supply chain effectiveness review as well as a planned study of electronic access controls for assets containing low impact BES cyber systems before it attempts any assessment of the standards’ adequacy.

‘Participant Funding’ Violates FPA, Grid Groups Say

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, renewable advocates said in a new report.

The report by the American Council on Renewable Energy and Americans for a Clean Energy Grid (ACEG) contends that the “participant funding” policy under FERC Order 2003 is “obsolete” and is hampering the transmission expansion needed to accommodate growing renewable generation.

Before the 2003 order, FERC required generators to pay 100% of “interconnection facilities” needed to establish the connection between the generator and the transmission network. The costs of “network facilities” — those at or beyond the point of interconnection needed to address stability and short-circuit issues — were initially funded by the generator but repaid through transmission credits. Order 2003 ended the crediting, which critics said diminished the incentive for interconnection customers to make efficient siting decisions.

The report’s authors said the order worked for gas-fired generation, which can interconnect in locations that avoid transmission constraints. “Transmission planning is less important with gas generation, as locational wholesale market prices and network upgrade costs assigned to interconnecting generators are able to direct gas generation investment to economically efficient locations,” they said.

But the authors said the policy doesn’t work for location-constrained wind and solar generation that now dominate interconnection queues. “Wind turbines located near the best wind resources are several times more productive than wind turbines at a typical site selected at random, while the best solar resource sites are about twice as productive as less optimal sites,” the authors said. “Wind and solar are also scalable and benefit from economies of scale, so most projects are large and built in remote areas where large amounts of land are available at low cost. As a result, these renewable projects often require larger transmission upgrades to serve load.”

Free Riders

The report contends the policy violates the Federal Power Act and results in “inefficiently small upgrades, raising costs to consumers.”

However, Rob Gramlich, executive director of ACEG and one of the authors of the report, said the two organizations have no plans to make a formal complaint to FERC. “We plan to issue another report in a week or so with what we think the real solution is — a comprehensive transmission planning rule,” he said. “It has been 10 years since the last such rule, Order 1000, which followed [Orders] 890 and 2000. ACEG will be sharing ideas broadly and hoping to stimulate discussion.”

The current policy means that after one project is assigned high-cost network upgrades, subsequent projects could use the additional capacity created without paying a fair share for the improvements. “Project developers, knowing there was a chance of getting lucky with a lower network upgrade cost assignment, had an incentive to enter multiple project proposals and multiple locations,” the report said. “Thus, many projects would enter queues, and many projects would cancel, leading to a cycle of continuous churn.”

Increasing Costs

In the past, interconnection charges for new renewables represented less than 10% of renewables projects’ total cost. Now, however, interconnection costs have risen so much they can represent 50% or more of project costs, according to the report.

“The system has reached a breaking point recently as spare transmission has been used up. Presently in most regions, new network capacity is needed for almost all of the projects in the queues,” it said. “When an increasing amount of location-constrained generation applies for interconnection in the same area, the grid begins to require not only ‘driveway’ type transmission facilities, but also bigger roads and highways. … What we are observing is that interconnection studies for individual generators (or groups of generators) are increasingly identifying costly regional upgrades.”

Participant Funding
Heat map shows MISO’s net first contingency incremental transfer capability (FCITC) as of 2016. Most of western MISO had an estimated deficit of 5 GW or more of transfer capacity to the rest of the region. “This means that at least that amount of transmission capacity must be constructed across MISO and into the PJM region before any new generation can be added,” says a report by ACORE and ACEG. | MISO

The authors cited research from Lawrence Berkeley National Laboratory that they said show that costs to integrate new generation “have reached levels that are unreasonably high for a developer to proceed in MISO and PJM.”

After Order 2003, MISO required generation owners to pay 100% of costs of network upgrades for lines below 345 kV and 90% for those above 345 kV. Wind projects in MISO, which historically paid about $66/kW to interconnect, are now being billed at $317/kW, five times as high.

MISO reported last year that it needs network upgrades exceeding $3 billion to accommodate the initial queue volume in its West region, a trend it expects to also hit its Central and South regions. (See MISO West Risks Becoming ‘Dead Zone,’ Stakeholders Warn.)

In PJM, interconnection costs for wind projects has risen to $54/kW from $19/kW while that for solar has more than doubled to $132/kW, from $62/kW. In 2019, a 120-MW solar-plus-storage project in southern Virginia was told it would face as much as $1.5 billion ($12,086/kW) in system upgrades, including the demolition and rebuilding of several 500-kV lines.

“The construction of large transmission lines required by some interconnection studies, which leads to such high network upgrade costs, are not isolated incidents,” the report said. “A number of offshore wind projects in PJM, for example, are expected to build long, 500-kV lines that are clearly network elements that benefit the entire region and should be planned and paid for through the regional planning process.”

Order 2003 allowed participant funding only in RTO and ISOs territories. In non-RTO areas, “where transmission upgrade costs are rolled into rates for all users, we do not find evidence of similar problems,” the report said.

Planning Reforms Needed

The authors said RTOs’ “siloed” transmission study processes, which consider reliability, economic and public policy transmission projects separately because of their different cost allocation methods, result “in a race that no one wants to win, as it will result in them bearing the cost for the transmission upgrades.”

“Each group of stakeholders attempts to free ride on other groups of stakeholders by failing to plan transmission that they would have to pay for, in the hope another group of stakeholders will plan and pay for it. Unfortunately, the typical result is that nobody builds the transmission, and all customers suffer from increased congested and reduced reliability.”

“Cluster” studies that analyze groups of generators simultaneously are an improvement, the authors said, but are limited because they consider only what is in the current queue. The report called for “proactive” transmission planning like the Competitive Renewable Energy Zones (CREZ) in ERCOT, Multi-Value Projects in MISO and priority projects in SPP that incorporate assumptions about wind and solar development and can maximize economic and reliability benefits.

Summer Readiness Sought by CAISO, CPUC

CAISO and the California Public Utilities Commission entered the new year trying to get ready for summer and avoid the shortfalls and rolling blackouts that plagued the state in August and September.

The CPUC on Friday proposed ordering the state’s three big investor-owned utilities — Pacific Gas and Electric, Southern California Edison and San Diego Gas & Electric — to contract for additional “incremental” capacity that can be ready this summer to meet heavy demand.

On Wednesday, CAISO held a meeting on the schedule and scope of a series of upcoming sessions to address “market enhancements for summer 2021 readiness.” Substantive meetings are scheduled to begin this week, with topics that include export and load scheduling priorities and resource sufficiency in the ISO’s interstate Western Energy Imbalance Market.

In the first week of 2021, CAISO conducted three days of meetings on its Resource Adequacy Enhancements stakeholder initiative, which started in 2018 but took on new urgency after last summer’s energy emergencies.

The ISO and stakeholders weighed a final draft proposal on the first phase of RA enhancements and a six-time-revised straw proposal on the initiative’s second phase. Items under discussion include RA import requirements, activating storage resources and rules on planned generator outages.

CAISO’s Board of Governors is scheduled to vote on the phase-one changes in March and on phase two in May and September

The ISO proceedings address issues raised in the preliminary root-cause analysis of the blackouts on Aug. 14-15 that affected more than 1 million residents during a severe heat wave that encompassed the Western U.S. Shortages occurred as solar power waned in the evening and there was insufficient capacity to meet continued high demand from air conditioning.

The October preliminary analysis, and a subsequent report by CAISO’s Department of Market Monitoring, identified problems that included inadequate RA planning, forced outages at power plants, a lack of storage for solar and wind resources, transmission constraints, imports that did not materialize and exports that should not have occurred in strained conditions. (See CAISO Wasn’t Gamed in Blackouts, Watchdog Finds.)

“The most significant and actionable of these factors involve California’s resource adequacy program,” the DMM’s November report said. “To limit the potential for similar conditions in future years, system level resource adequacy requirements should be modified to ensure more capacity is available during net load peak hours,” as solar ramps down but demand stays high.

Supply is tightening across the West as coal and “older baseload” fossil-fuel and nuclear plants retire, CAISO staff members noted during an RA enhancements meeting Wednesday.

“Severe weather events have become more common and have impacted … several BAs at the same time, further tightening system conditions,” said Milos Bosanac, CAISO lead infrastructure and regulatory policy developer. Heat waves could continue to pummel the West in the future and limit imports, Bosanac said in his presentation.

To head off shortfalls, RA imports must be linked to specific generating resources in other states, he said. That is not the situation now. If supply is not connected to a physical source, “it poses a risk to supply not being committed to the CAISO when it matters most, when conditions are tight,” he said.

In addition, the ISO wants firm commitments from transmission owners to prioritize RA imports during times of tight supply. Transmission lines from the Pacific Northwest to California can become nearly maxed-out during heat waves, Bosanac noted.

Much of California’s import RA capacity comes from the Bonneville Power Administration over the California-Oregon AC intertie (COB) and the Nevada-Oregon Border DC Intertie (NOB), he said. Those interties will require the highest guarantee of transmission capacity, he said.

“Looking at particularly the COB and NOB interties, usually on those last legs of those interties … especially in the summer months, flows tend to reach or be very close to the limits of those path, Bosanac said. “[With] a higher likelihood of curtailment … it’s important that these deliveries be on the highest priority transmission service to minimize that risk of curtailment so that those imports can be delivered to the CAISO.”

Some stakeholders question the plan because they worry it could lead to the exercise of market power. (See CAISO Seeks ‘Firm’ Tx for Resource Adequacy.)

During an RA meeting Thursday, Doug Boccignone, a principal at Flynn Resource Consultants representing the California Community Choice Association, said only five parties control half the transmission import capability on COB and NOB.

“The rights are really concentrated,” Boccignone said. “It makes me concerned that if California is dependent on imports from the Northwest to meet the resource adequacy requirements … there’s the potential for those parties that control those rights to be in a much different position than they are today.”

CAISO said there are 21 parties that hold transmission rights on the two interties. Bridget Sparks, infrastructure and regulatory policy developer, said the ISO’s analysis did not show a high risk for the entities to exert market power.

“If we think of the market as COB and NOB combined … there is a slight market concentration, [but] it’s nowhere near a monopolistic control,” Sparks said.

SPP Stakeholders Fill Open Committee Positions

SPP’s Corporate Governance Committee last week approved nominations for several open positions on stakeholder groups. The nominations will go before the Board of Directors on Jan. 26 for final approval.

Members selected Sunflower Electric Power’s Al Tamimi and NextEra Energy’s Matt Pawlowski to fill contested open positions on the Finance Committee. Tamimi, a familiar face for years in SPP stakeholder meetings, will represent the transmission-owning (TO) sector and Pawlowski the transmission-using (TU) sector.

SPP Committee
SPP’s Corporate Governance Committee hears from applicants for open committee positions. | SPP

The CGC also approved Oklahoma Gas & Electric’s Usha Turner as an investor-owned utility sector representative on the Members Committee. She replaces Greg McAuley, who left OG&E in December to return to his native Florida.

Turner, director of federal and regional policy for the utility, said she has absorbed McAuley’s RTO policy responsibilities into her existing role.

OGE Energy’s Scott Briggs and Arkansas Electric Cooperative’s Maria Bunting Smedley were recommended to fill positions on the Human Resources Committee representing the TO and TU sectors, respectively.

The CGC endorsed Northeast Texas Electric Cooperative CFO Caleb Head as chair of the Credit Practices Working Group.

SPP, MISO See $22.8M in M2M Settlements

SPP staff assured stakeholders they are looking into the causes of congestion around the MISO seam following a third straight month of record market-to-market (M2M) settlements.

SPP incurred $22.87 million from MISO in M2M settlements during November, a 56.3% increase from the $14.63 million in October. That mark more than doubled the previous high. (See Record $14.63M M2M Settlement for SPP, MISO.)

“Some of it [the spike in M2M settlements] is a ‘perfect storm’ scenario,” SPP’s Scott Brown told the Seams Steering Committee on Friday. “It was a combination of significant outages in certain areas, increased wind and a low mix of [firm-flow] entitlements [FFEs] in the areas where there is an increased use of the system along the seam.”

FFEs are allocated property rights to the RTOs, with each RTO calculating its real-time usage. The grid operators exchange M2M settlements for redispatch based on the non-monitoring RTO’s market flow in relation to its FFE.

“In general, one of the major causes for these M2M events and settlements is when the wind is high in both SPP and MISO,” said Clint Savoy, the SSC’s staff secretary.

SPP MISO
Market-to-market settlements between SPP and MISO have set records for three straight months. | SPP

Ten permanent flowgates were binding for 525 hours, resulting in $11.77 million in M2M settlements, while 36 temporary flowgates bound for 1,612 hours, accounting for $11.1 million in payments.

Pointing to a trouble spot on the western side of the Nebraska-Iowa border, SPP Director of System Planning Casey Cathey reminded the committee that the grid operator identified a potential interregional transmission project in the area last year. It failed to meet MISO’s benefit-to-cost ratio threshold.

The 161-kV Raun-Tekamah permanent flowgate in eastern Nebraska accounted for almost $5 million in settlements to SPP alone, binding for 198 hours. Cathey said the Raun area is one of the highest priorities for SPP’s 2021 Integrated Transmission Planning assessment and the joint transmission study with MISO. (See MISO, SPP Stakeholders Applaud New Joint Study.)

SPP MISO
Casey Cathey, SPP | © RTO Insider

“You look at the locations of the [generator interconnection] queue for SPP and the locations of the queue for MISO, and intuitively, without running any studies, you understand that unless we build bigger pipes — more transmission — [the Raun area’s congestion] is going to continue,” Cathey said.

“It’s not going to drop down, but I don’t know that the magnitude will be as high for a sustainable period,” he said. “There’s nothing in the works that alleviates this congested area. The trend will continue, just not to that magnitude.”

Cathey hopes the Strategic and Creative Re-engineering of Integrated Planning Team (SCRIPT), which has been tasked with reviewing and possibly combining SPP’s seven different transmission planning processes, will be able to relieve some of the pressures on the grid. (See “SPC Takes Look at Tx Planning,” SPP Briefs: Week of Aug. 31, 2020.)

“All these different business functions operate on different timelines and for different reasons. I’m not saying it’s broken, but this is what happens,” he said. “That’s the big part of what we’re trying to do with SCRIPT and consolidation.”

SPP has piled up $140.23 million in settlements from MISO since the two grid operators began the M2M process. Under the process, the monitoring and non-monitoring RTOs manage M2M constraints by exchanging shadow prices and other information to ensure that the RTO with the more economic dispatch addresses flows. The shadow price indicates the marginal value of an additional increment of relief on a congested constraint in reducing the total production costs.

M2M settlements have been in SPP’s favor 13 of the last 14 months and 52 times in 69 months since the process began in 2015. The top 10 constrained flowgates since the process began all have MISO paying SPP, staff said.

SSC Supports Affected-system Studies

The SSC told staff it would approve a proposal to revise the queue priority for transmission projects in affected-systems studies with seams neighbors, but only if they are applied to all neighboring grid operators.

A majority of stakeholders in a snap poll during Friday’s webinar said they would support Associated Electric Cooperative Inc.’s (AECI) proposal to establish a relative queue priority for study requests between the cooperative and AECI.

Only three of the 15 respondents to the poll said they would not support AECI’s proposal.

Staff are also gathering feedback from the Generation Interconnection Users Forum.

SPP uses the studies to determine non-jurisdictional and neighboring interconnection requests’ effects on its transmission system. The studies take into account interconnection requests on neighboring grids, including those of AECI, MISO, Minnkota Power Cooperative and NorthWestern Energy.

PJM, States Exploring 6 Scenarios in OSW Tx Study

PJM and state officials seeking the most efficient way to integrate more than 12 GW of offshore wind generation have identified six scenarios for analysis in a study expected to produce results after mid-2021, the RTO told the Transmission Expansion Advisory Committee Wednesday.

The Offshore Transmission Study Group, which was created in response to a request by the Organization of PJM States Inc., developed the scenarios during five meetings since October 2020, Matthew Bernstein, PJM analyst for state policy solutions, told the TEAC. PJM staff also held one-on-one meetings with individual states, he said.

The scenarios will consider the magnitude, points of interconnection and timing of OSW injections for both announced and planned projects. The analyses will also consider the impact of generator deactivations and states’ clean energy goals, Bernstein said.

PJM may study additional scenarios based on the initial study findings and feedback from the states, he continued.

PJM OSW

Within PJM, New Jersey (6.4 GW), Virginia (5.2 GW) and Maryland (1.2 GW) have announced OSW goals.

Bernstein said the analyses are directed at upgrades that will be necessary for the onshore system and will not consider offshore infrastructure such as a mesh network grid or collector stations.

“We’re looking at what these different offshore wind injections are going to do to the onshore system,” Bernstein said. “We’re still in the process of developing these scenarios and have not begun the actual analysis itself.”

Stakeholder Questions

PJM OSW
Theodore Paradise, Anbaric | © RTO Insider

Theodore Paradise, senior vice president of transmission strategy for Anbaric Development Partners, asked how the modeling efforts relate to the New Jersey Board of Public Utilities’ request in November that PJM integrate the state’s OSW goals into the RTO’s Regional Transmission Expansion Plan. New Jersey’s request made it the first state to embrace the state agreement approach under FERC Order 1000, which allows states to fund transmission projects needed to meet public policy needs.

PJM expects to open a competitive solicitation window including New Jersey’s request in the first quarter of 2021. (See NJ Asks PJM to Seek Bids for OSW Tx.)

Bernstein said the assumptions and analysis of the onshore component developed in response to New Jersey’s request will be incorporated into the study.

PJM OSW
Sharon Segner, LS Power | © RTO Insider

“You can look at this as incorporating the other states’ offshore wind objectives around what we’ve already done with New Jersey as part of a larger collaborative effort,” he said.

Sharon Segner, vice president of LS Power, said the goal of having a more active public policy planning process is “really encouraging.” Segner asked if PJM anticipates the scenarios will be made public before the results are produced.

Bernstein said it is “too early” to tell what will be made available to stakeholders and when. He said the scenarios will be described in the final report.

Segner said PJM’s presentation made it seem as if the RTO was attempting to identify regional transmission solutions to accommodate states’ OSW goals. She said typically in these types of scenarios, each would be put into the planning windows and the parties would be developing and proposing regional transmission solutions.

“I’m not completely understanding how this fits into the process,” Segner said. “It sounds like an interesting development, but I’m just trying to put the pieces together.”

PJM OSW
Mark Sims, PJM | © RTO Insider

Mark Sims, PJM’s manager of infrastructure coordination, said Segner was jumping a bit too far ahead in the process. Sims said there’s still education that needs to be completed on the issue before PJM decides how to implement the potential solutions a state decides to move forward with.

Sims said the goal is to identify what the states want to accomplish, develop assumptions, run the studies and give information on possible results.

“If any state or group of states decides to move forward, we envision that’s when the competitive process would play a role,” he said.