The independent administrator of Maine's energy efficiency programs has issued a request for information to inform a study of the barriers to beneficial electrification in the transportation and heating sectors in Maine. While the electricity sector has largely been decarbonized, transportation and heating lag significantly: Maine's transportation sector was responsible for 53 percent of the state's greenhouse gas emissions in 2017,
with heating taking the next greatest share. Meanwhile, electricity
generation in Maine accounted for just 9 percent of the state's
greenhouse gas emissions.
Earlier this year, the Maine legislature enacted a law supporting "beneficial electrification", a concept defined in the new statute as "electrification of a technology that results in reduction in the use of a fossil fuel, including electrification of a technology that would otherwise require energy from a fossil fuel, and that provides a benefit to a utility, a ratepayer or the environment, without causing harm to utilities, ratepayers or the environment, by improving the efficiency of the electricity grid or reducing consumer costs or emissions, including carbon emissions." For example, petroleum used as fuel for vehicles and heating could be replaced by electricity generated from cleaner and less costly sources.
The new law also requires Efficiency Maine Trust -- Maine's quasi-governmental independent efficiency program administrator -- to study barriers to beneficial electrification in Maine's transportation and heating sectors. To inform that study, on August 28, 2019, Efficiency Maine Trust released its Request for Information on Beneficial Electrification Study. It requests that interested parties submit written information, guidance, or comments relevant to the study, including barriers to beneficial electrification of transportation and heating, potential roles of utilities in supporting beneficial electrification, areas or populations where additional policy development or utility intervention are needed to ensure the benefits of beneficial electrification are obtained, and recommended opportunities for beneficial electrification. The Trust has requested written comments by September 18, 2019.
Separately, under another section of the new law, the Maine Public Utilities Commission has issued a request for proposals for pilot programs that support beneficial electrification of the transportation sector. The Commission's August 28 Request for Proposals seeks proposals for "pilot programs and projects that are limited in duration and scope to support beneficial electrification of the transportation sector." It suggests that proposals may address electric vehicle chargers that make use of load management, utility investment in electricity delivery infrastructure for fast-charge direct-current technology, fees for this service, and recommended opportunities for deployment.
Energy powers society; society's choices shape energy policy. A blog about our energy resources and the choices they present for society.
FERC/NERC joint white paper on cyber transparency
Tuesday, August 27, 2019
U.S. electricity regulators have asked for public comment on a staff white paper proposing to provide increased transparency and public access to information on violations of mandatory reliability standards governing cybersecurity of the bulk electric system, while protecting sensitive information whose disclosure would be a security risk. If the changes are adopted, the identity of violators would be made public, while detailed information that could be useful in planning an attack on critical infrastructure would remain protected from public disclosure.
At issue is a white paper jointly prepared by staff of the Federal Energy Regulatory Commission and of North American Electric Reliability Corporation (NERC). The Joint Staff White Paper on Notices of Penalty Pertaining to Violations of Critical Infrastructure Protection Reliability Standards was released on August 27, 2019.
The Commission's regulatory jurisdiction includes cybersecurity issues affecting the bulk electric system. NERC, in its role as the nation's electric reliability organization, has adopted a variety of reliability standards, including those governing Critical Infrastructure Protection (CIP) and cybersecurity of the grid. Since 2010, NERC has submitted Notices of Penalty to FERC pertaining to violations of its CIP standards, which typically describe the nature of the violations, potential cyber system vulnerabilities, and mitigation activities, but which do not publicly identify the entity alleged to have violated the standards.
But according to the Commission, since 2018 it has received an "unprecedented number" of Freedom of Information Act requests for non-public information in these Notices of Penalty, such as the identity of the entity alleged to have violated the standard. For example, earlier this year a nongovernmental organization unsuccessfully pressured the Commission to identify an anonymous utility that had agreed to pay a $10 million penalty to settle allegations of violations of cybersecurity and other reliability standards.
To refine the balance between transparency and security, the joint white paper proposes that NERC would submit each notice with a public cover letter that discloses the name of the violator, which reliability standards were violated, and the amount of penalties assessed. Separate non-public attachments would detail the nature of the violation, mitigation activity and potential vulnerabilities to cyber systems, with such information designated as Critical Energy Infrastructure Information and subject to additional protections. According to the Commission, these proposed changes will facilitate distinguishing between public and non-public information.
The Commission has issued a Notice of White Paper, calling for public comments to be filled within 30 days. The Commission has specifically asked for comment on the potential security benefits and risks associated with this approach; difficulties with implementation or other concerns that should be considered; and the level of transparency provided by this proposed change.
At issue is a white paper jointly prepared by staff of the Federal Energy Regulatory Commission and of North American Electric Reliability Corporation (NERC). The Joint Staff White Paper on Notices of Penalty Pertaining to Violations of Critical Infrastructure Protection Reliability Standards was released on August 27, 2019.
The Commission's regulatory jurisdiction includes cybersecurity issues affecting the bulk electric system. NERC, in its role as the nation's electric reliability organization, has adopted a variety of reliability standards, including those governing Critical Infrastructure Protection (CIP) and cybersecurity of the grid. Since 2010, NERC has submitted Notices of Penalty to FERC pertaining to violations of its CIP standards, which typically describe the nature of the violations, potential cyber system vulnerabilities, and mitigation activities, but which do not publicly identify the entity alleged to have violated the standards.
But according to the Commission, since 2018 it has received an "unprecedented number" of Freedom of Information Act requests for non-public information in these Notices of Penalty, such as the identity of the entity alleged to have violated the standard. For example, earlier this year a nongovernmental organization unsuccessfully pressured the Commission to identify an anonymous utility that had agreed to pay a $10 million penalty to settle allegations of violations of cybersecurity and other reliability standards.
To refine the balance between transparency and security, the joint white paper proposes that NERC would submit each notice with a public cover letter that discloses the name of the violator, which reliability standards were violated, and the amount of penalties assessed. Separate non-public attachments would detail the nature of the violation, mitigation activity and potential vulnerabilities to cyber systems, with such information designated as Critical Energy Infrastructure Information and subject to additional protections. According to the Commission, these proposed changes will facilitate distinguishing between public and non-public information.
The Commission has issued a Notice of White Paper, calling for public comments to be filled within 30 days. The Commission has specifically asked for comment on the potential security benefits and risks associated with this approach; difficulties with implementation or other concerns that should be considered; and the level of transparency provided by this proposed change.
U.S. electric utility ownership types
Monday, August 19, 2019
Investor-owned electric distribution companies served 72% of U.S. electricity customers in 2017 according to federal data, even though investor-owned utilities accounted for just 168 out of nearly 3,000 electric utilities.
The U.S. Energy Information Administration categorizes electric utilities into three groups based on their ownership type: investor-owned utilities, publicly owned utilities, and cooperatives. Stock in investor-owned utilities is owned by shareholders; publicly owned utilities include those run by federal, state and municipal entities; cooperatives are not-for-profit utilities owned by their customer-members.
Of the nearly 3,000 electric distribution companies operating in the United States in 2017, just 168 were investor-owned -- but these investor-owned utilities or IOUs tend to be much larger than others, serving an average of 654,600 customers, and in the aggregate providing power to nearly three-quarters of all U.S. electricity customers. According to EIA, IOUs tend to be concentrated in heavily populated areas on the East and West coasts. For example, two California utilities each serve over 5 million electricity customers.
Publicly owned utilities are most numerous, with 1,958 operating in 2017 according to EIA data. On average, each publicly owned utility services 12,100 electricity customers, or about 15% of all U.S. electricity customers in total.
812 electric cooperatives or co-ops are located across 47 U.S. states, serving an average of 24,500 electricity customers each. Interest in cooperative and publicly owned utility forms is increasing, as consumers and policymakers look for structures that balance economic and environmental efficiencies against responsiveness and local control.
The U.S. Energy Information Administration categorizes electric utilities into three groups based on their ownership type: investor-owned utilities, publicly owned utilities, and cooperatives. Stock in investor-owned utilities is owned by shareholders; publicly owned utilities include those run by federal, state and municipal entities; cooperatives are not-for-profit utilities owned by their customer-members.
Of the nearly 3,000 electric distribution companies operating in the United States in 2017, just 168 were investor-owned -- but these investor-owned utilities or IOUs tend to be much larger than others, serving an average of 654,600 customers, and in the aggregate providing power to nearly three-quarters of all U.S. electricity customers. According to EIA, IOUs tend to be concentrated in heavily populated areas on the East and West coasts. For example, two California utilities each serve over 5 million electricity customers.
Publicly owned utilities are most numerous, with 1,958 operating in 2017 according to EIA data. On average, each publicly owned utility services 12,100 electricity customers, or about 15% of all U.S. electricity customers in total.
812 electric cooperatives or co-ops are located across 47 U.S. states, serving an average of 24,500 electricity customers each. Interest in cooperative and publicly owned utility forms is increasing, as consumers and policymakers look for structures that balance economic and environmental efficiencies against responsiveness and local control.
NY agencies complain grid rules penalize storage
Friday, August 2, 2019
New York state energy agencies have complained to federal regulators that the New York electric grid operator's market rules are interfering with the state's policies supporting the increased deployment of energy storage resources.
In a complaint filed on July 29, 2019 with the Federal Energy Regulatory Commission, the New York State Public Service Commission and New York State Energy Research and Development Authority assert that the development of energy storage resources in New York is necessary for legitimate state purposes, such as "enhancing reliability, resilience, and fuel diversity, as well as reducing environmental and public health impacts associated with fossil fuel emissions." New York has announced $400 million in funding for energy storage initiatives, and has released an implementation plan for energy storage market acceleration.
However, in their complaint the agencies note that development is frustrated by market rules adopted by the New York Independent System Operator. In particular, the state agencies point to NYISO tariff provisions that require energy storage resources participating in the wholesale installed capacity (ICAP) market to be subject to buyer-side mitigation measures which "would severely limit, or even eliminate, the ability of Energy Storage Resources to be paid for the value they provide."
According to a draft NYISO presentation on buyer side mitigation posted on the grid operator's website, buyer-side mitigation or BSM is one tool NYISO uses to "mitigate the market effects of conduct that would substantially distort competitive outcomes in the ISO Administered Markets, while avoiding unnecessary interference with competitive price signals." Specifically, the presentation describes buyer side mitigation's purpose as "to prevent uneconomic entry from artificially suppressing capacity prices." Resources that are subject to the buyer side mitigation rule will be examined in a two-part test to determine whether a minimum "offer floor" will be imposed.
The complainants request "that the Commission preserve the cooperative federalism approach" by the Federal Power Act and grant a blanket exemption from the buyer-side mitigation measures for all energy storage resources that seek to participate in the NYISO's ICAP auctions, or at least enable up to 300 megawatts to energy storage resources to enter the market each calendar year without the threat of mitigation.
The Federal Energy Regulatory Commission has taken a variety of actions in recent years to accommodate the entry of electric energy storage facilities into the grid and wholesale markets, including Order No. 841 and 841-A which established reforms to remove barriers to the participation of electric storage resources in certain organized wholesale markets. The New York agencies' complaint remains pending as of the end of July 2019, with public comment solicited until 5:00 pm Eastern Time on August 19, 2019.
In a complaint filed on July 29, 2019 with the Federal Energy Regulatory Commission, the New York State Public Service Commission and New York State Energy Research and Development Authority assert that the development of energy storage resources in New York is necessary for legitimate state purposes, such as "enhancing reliability, resilience, and fuel diversity, as well as reducing environmental and public health impacts associated with fossil fuel emissions." New York has announced $400 million in funding for energy storage initiatives, and has released an implementation plan for energy storage market acceleration.
However, in their complaint the agencies note that development is frustrated by market rules adopted by the New York Independent System Operator. In particular, the state agencies point to NYISO tariff provisions that require energy storage resources participating in the wholesale installed capacity (ICAP) market to be subject to buyer-side mitigation measures which "would severely limit, or even eliminate, the ability of Energy Storage Resources to be paid for the value they provide."
According to a draft NYISO presentation on buyer side mitigation posted on the grid operator's website, buyer-side mitigation or BSM is one tool NYISO uses to "mitigate the market effects of conduct that would substantially distort competitive outcomes in the ISO Administered Markets, while avoiding unnecessary interference with competitive price signals." Specifically, the presentation describes buyer side mitigation's purpose as "to prevent uneconomic entry from artificially suppressing capacity prices." Resources that are subject to the buyer side mitigation rule will be examined in a two-part test to determine whether a minimum "offer floor" will be imposed.
The complainants request "that the Commission preserve the cooperative federalism approach" by the Federal Power Act and grant a blanket exemption from the buyer-side mitigation measures for all energy storage resources that seek to participate in the NYISO's ICAP auctions, or at least enable up to 300 megawatts to energy storage resources to enter the market each calendar year without the threat of mitigation.
The Federal Energy Regulatory Commission has taken a variety of actions in recent years to accommodate the entry of electric energy storage facilities into the grid and wholesale markets, including Order No. 841 and 841-A which established reforms to remove barriers to the participation of electric storage resources in certain organized wholesale markets. The New York agencies' complaint remains pending as of the end of July 2019, with public comment solicited until 5:00 pm Eastern Time on August 19, 2019.
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