FERC

When customers sell demand response into a regional capacity market (such as PJM’s Reliability Pricing Model, known as the RPM), how much credit should they earn for agreeing to curtail demand and alleviating stress on the grid — that is, for reducing the market’s need for generating capability and capacity reserve margin? And further, should the amount of credit depend on whether the customer works with market aggregators, known both as CSPs (“Curtailment Service Providers”) or ARCs (“Aggregators of Retail Customers”)? One view would pay customers for the full extent of their curtailment of demand — known as its “Guaranteed Load Drop” (GLD). The other would limit capacity credit to the customer’s prior load history — “Peak Load Contribution,” or PLC. The answer may well dictate whether regulators continue to treat “energy” and “capacity” as two distinct concepts.

The wind power industry has been up in arms ever since the Bonneville Power Administration earlier this year announced its Interim Environmental Redispatch and Negative Pricing Policy. That policy, applicable during periods of high spring runoff and heavy water flow volumes on the Federal Columbia River Power System, calls for BPA to redispatch and curtail access to transmission for wind power generating turbines, and to replace that resource with hydroelectric power generated via BOA hydroelectric dams, in order to avoid having to divert water through dam spillways, which could threaten fish and wildlife by creating excess levels of Total Dissolved Gas (TDG), which can cause Gas Bubble Trauma. Yet the legal issue remains unclear: Does this practice imply discrimination in the provision of transmission service, or is it simply a matter of system balancing and generation dispatch? In fact, the FERC may lack jurisdiction over the dispute, as it pertains to the fulfillment of BPA’s statutory mandates.

The recent landmark ruling on transmission planning cost allocation, known as “Order 1000,” and issued by the U.S. Federal Energy Regulatory Commission in late July 2011, could well produce an unintended side effect — the formation of regional compacts among states to identify needs and plan for development of new power plant projects.

(August 2011) Economic consultant Michael Rosenzweig challenges Constantine Gonatas’s proposal for ensuring FERC’s demand response rulemaking achieves its objectives. Also, Juliet Shavit takes issue with Contributing Editor Steven Andersen’s characterization of utility customers as “crazy.”

When the U.S. Federal Energy Regulatory Commission issued its so-called ”MOPR“ decision in April 2011, approving a minimum offer price rule (or bid floor) for PJM RPM capacity market — and then on the very next day did much the same for New England’s FCM capacity market — FERC did more than just prop up prices. Instead, it created a nightmare scenario for utilities that still own their own generation. These utilities, who choose to “self-supply” with their own plants, rather than buy capacity from either the RPM or FCM, adequacy rules, could now be forced to pay twice for capacity — if their own plants are deemed inefficient or uneconomic.

Four years ago, Congress made its wishes known: it tabbed the National Institute of Standards and Technology to develop a set of standards for the smart grid, and then instructed FERC, the Federal Energy Regulatory Commission “adopt” those standards, but only after finding a ”sufficient consensus,” and only “as may be necessary” to assure “functionality and interoperability.” Yet what is known is not necessarily clear. Who decides if consensus prevails? What does “interoperability” mean? Should FERC’s “necessary” finding extend to retail smart grid applications, arguably outside its purview? And the biggest dispute — must standards be mandatory? — finds PJM at odds with much of the utility industry.

Competitive energy suppliers are infuriated by Michigan’s regulatory framework. The state partially unbundled its utilities, but left generation tied to retail operations. Then it opened the retail market to alternative suppliers, but capped their participation at 10 percent — severely limiting true competition. Former FERC Commissioner Bill Massey says Michigan’s schizophrenic approach is stifling innovation and saddling customers with unnecessary risks and costs.

Touted as the nation’s first-ever “offshore transmission highway,” the proposed Atlantic Wind Connection (AWC) high-voltage power line in theory could foster dozens of wind farms in shallow offshore costal waters up and down the mid-Atlantic seaboard — but only if federal regulators can get buy-in for new transmission planning rules that give precedence to large, macro projects aimed at boosting renewable energy. Otherwise, the grid project might never pass muster with the engineers charged with OK’ing new power lines, since the AWC is probably not needed to maintain reliability, and likely would not make electricity rates any cheaper for East Coast ratepayers. Should wind energy developers start with massive grid projects to attract clusters of wind turbines, or should the wind farms come first?

Despite the variable nature of the resource, wind can be managed so that it will not impair the reliability of a utility system. The Federal Energy Regulatory Commission proposed a rule that would require changes to the way transmission service is scheduled, which would enhance the ability of balancing authorities to integrate wind.

Are the Feds at war with green power development? You might have thought so, if you had sat through the conference held March 15, 2011, at the Federal Energy Regulatory Commission, where the consensus seemed to be that FERC’s policy of granting open-access rights on electric transmission lines is problematic for green power projects. In short, when wind and solar developers choose to build their own local tie lines to link their projects to the larger grid, FERC policy forces them to make extra line capacity available to rival developers. That requirement doomed the novel Wind Spirit Project, and continues to complicate the job of project financing.