FERC approves energy storage tariffs

U.S. utility regulators have approved the first two regional implementations of a landmark 2018 order designed to remove barriers to the participation of electricity storage in wholesale markets.

In 2018, the Federal Energy Regulatory Commission issued its Order No. 841, requiring each organized power market to revise its tariff to establish a "participation model" for electric storage resources in the capacity, energy and ancillary service markets. The rule requires each market's participation model to include market rules that recognize the physical and operational characteristics of electric storage resources and facilitate their participation in those markets. The Commission later affirmed the rule, through its Order No. 841-A.

Last week, the Commission issued two orders approving Order No. 841 compliance filings by Southwest Power Pool, Inc. and by PJM Interconnection. The Commission generally found that the SPP and PJM tariff revisions complied with the new rule, and largely accepted their filings. For example, the Commission found that both proposals "generally enable electric storage resources to provide all services they are capable of providing; allow electric storage resources to be compensated for those services in the same manner as other resources; and appropriately recognize the unique physical and operational characteristics of electric storage resources."

However, the Commission also provided directives for further compliance filings by SPP and PJM to be made within 60 days. The Commission found that while both filed tariffs generally satisfy Order No. 841’s directive allowing electric storage resources to de-rate their capacity to meet minimum run-time requirements, neither tariff included minimum run-time requirements for resource adequacy and capacity, respectively. Because "such requirements affect rates, terms and conditions of service," the Commission initiated proceedings under section 206 of the Federal Power Act to address the specific issue of minimum run-time requirements.

In a pair of separate statements (on SPP and on PJM), Commissioner McNamee concurred with the orders insofar as they found compliance with the Commission's orders and regulations. But Commissioner McNamee said, "I write separately, however, to express my continuing concern that the Commission exceeded its statutory authority under the Federal Power Act, and should have, at the very least, provided states the opportunity to opt-out of the participation model created by the Storage Orders." Commissioner McNamee also reiterated jurisdictional concerns he had previously raised in a partial concurrence to and partial dissent from Order No. 841-A, "to the extent the Commission’s Storage Orders exercised authority over the distribution system and behind-the-meter."

Other organized wholesale market operators, such as ISO New England, Inc., are also adopting tariff revisions to comply with Order No. 841, to enhance the ability of electric storage facilities to participate in regional wholesale electricity markets.

New England 2019 Regional Energy Outlook describes shifts, challenges

New England's electricity system is shifting toward a "hybrid grid," according to the operator of New England's wholesale electricity markets and electric transmission system. A recent report by ISO New England, Inc. describes the electric sector's transition towards generating resources with lower carbon emissions and the resulting implications for the environment and the economy.

ISO New England is the federally-designated regional transmission organization serving New England. The grid operator recently released its 2019 Regional Energy Outlook, a document described as “one of the many ways the ISO keeps stakeholders informed about the current state of the grid, issues affecting its future, and ISO initiatives to ensure a modern, reliable power system for New England.”

In the report, ISO New England emphasizes the region’s decarbonization and shifting resource mix, noting that “carbon emissions from the grid have fallen by roughly a third... the region is on its way from having an electric grid dominated by fossil-fuel and nuclear generation to one that includes large amounts of wind and hydro generation and hundreds of thousands of small solar and storage systems spanning the six states. The states’ next step in their decarbonization journey is to transition the emissions-heavy heating and transportation sectors to low-carbon electricity.”

ISO-NE describes the way these changes are happening as “challenging reliable system operations and competitive wholesale electricity markets.” ISO says that “for the foreseeable future, the region will remain vulnerable to energy shortfalls and wholesale price volatility as more and more resources with limited-energy ‘inventories’ (natural gas generation, wind, solar, battery storage) displace resources with on-site fuel that can sustain operation for extended periods (oil, coal, nuclear, dual-fuel generation).”

ISO New England says its competitive markets weren’t designed to telegraph future energy scarcity conditions, compensate resources for fuel inventory, achieve carbon reduction goals, or specifically lead to renewable development. It notes that state-sponsored resources suppress market prices when in markets, but would lead to overbuild if outside markets. ISO advocates, “Establishing a realistic price on carbon remains a more seamless and simpler way to achieve clean-energy goals through markets without distorting competition, but this is not in the ISO’s jurisdiction. State or federal policymakers could pursue this direction but have not done so to date.” ISO notes, “Nuclear resources will prove critical to meeting both decarbonization and energy-security goals for years to come, but how they can remain financially viable is still unclear.”

ISO-NE says it is focused on 3 elements to support the transition to the “hybrid grid”: supporting the rapid transformation of the region’s electricity supply and demand mix, maintaining a robust transmission system, and ensuring energy security. 

The grid operator also noted limitations on what tools it can use to address these challenges: “Importantly, ISO New England does not have the authority to dictate investments in energy infrastructure that can help ensure that the region’s energy needs can be met in all seasons, under all conditions. Our toolkit is to create financial stimuli through the wholesale electricity markets that will drive action. Opposition or impediments to infrastructure decisions will only exacerbate the region’s energy-security constraints.”

New England regional renewables procurement

As states enact and pursue energy policy goals such as sourcing power from solar, offshore wind, or other "clean energy" resources, here's a quick look at some of the regional renewable procurement activity ongoing in New England: 

New England Clean Energy RFP: This "three-State Clean Energy RFP" focused on Massachusetts, Connecticut, and Rhode Island.  Although each state enacted its own statutory framework for procurement, soliciting parties including the Connecticut Department of Energy and Environmental Policy and utilities in Massachusetts and Rhode Island released a joint Request for Proposals in September 2015.  Bids were due by January 28, 2016.  Following an evaluation period, bidders were selected for contract negotiation and notified on October 24, 2016.  The states collectively selected the following proposals representing approximately 460 megawatts in total:

Massachusetts/Connecticut/RI
Antrim Wind
Ranger Solar
Cassadaga Wind
RES Americas – Both Submissions(1 and 2)
Massachusetts/RI
Deepwater Wind
Ameresco

Massachusetts Section 83C RFP for Long-term Contracts for Offshore Wind Energy: A 2016 state law requires utilities to competitively solicit and contract for approximately 1,600 megawatts of offshore wind, starting by June 30, 2017.  On April 28, 2017, submitted their proposed RFP to the Massachusetts Department of Public Utilities for review and approval.  Through the RFP, the utilities will seek proposals for “Offshore Wind Energy Generation” and associated transmission necessary to deliver such generation to the mainland ISO New England, Inc. grid.  According to the proposed timeline, bids would be due in December 2017, with project selection in May 2018.

Massachusetts Section 83D RFP for Long-term Contracts for Clean Energy: On March 31, 2017, the Massachusetts Electric Distribution companies, in coordination with the Massachusetts Department of Energy Resources, issued a Request for Proposals for Long-term Contracts for Clean Energy Projects pursuant to Section 83D of Chapter 169 of the Acts of 2008, as amended by chapter 188 of the Acts of 2016, An Act to Promote Energy Diversity.  Bids are due by July 27, 2017, with project selection expected in January 2018.

Will clustering help New England's interconnection queue?

Faced with a persistent backlog of requests to interconnect to the electric grid across parts of New England, will the region's major grid operator adopt a "clustering" methodology to streamline the study process and reduce procedural delays?

At issue are ISO New England's interconnection procedures, which govern the process through which generators and transmission lines may interconnect to the New England bulk power system.  For nearly all large projects and some smaller ones, ISO-NE administers the process and conducts extensive engineering studies to determine whether such interconnections would be feasible without adversely affecting reliability and how they should be accomplished.  In general, ISO-NE uses a first-come, first-served basis: a project's impacts on the grid are studied in sequential order based on that project's position in the interconnection queue.  In practice, this means that a project's studies do not commence until the studies for projects ahead in line are complete.

According to ISO-NE, this system has worked well for most of the region.  Excluding northern and western Maine, the grid operator reports that on average, system impact studies are completed within a year of the customer's interconnection request.  But ISO-NE notes that its "Interconnection Queue has experienced a persistent backlog of requests to interconnect in northern & western Maine."  Many of these requests relate to wind projects located relatively far from the transmission system, but similar challenges could arise relating to large solar projects in parts of Maine, Vermont, or New Hampshire.

The grid operator may be able to address this backlog by changing its interconnection procedures to be more in line those adopted in other regions, by allowing "clustering" or pooled and simultaneous study of certain resources. As described by ISO-NE in a presentation delivered last year, all of the other Independent System Operators or Regional Transmission Organizations -- such as NYISO, PJM, MISO, CAISO, and SPP - include some form of clustering in the interconnection process; New England stakeholders have requested that ISO-NE investigate clustering; and the Federal Energy Regulatory Commission has also addressed clustering, including in a May 2016 technical conference.

ISO-NE's proposed clustering methodology would allow, under specific circumstances, for two or more Interconnection Requests to be analyzed in the same System Impact Study (SIS) effort.  Projects participating in a cluster would share cost responsibility for certain shared interconnection related transmission upgrades, known as Cluster Enabling Transmission Upgrades (CETU), identified by ISO-NE as necessary for the applicable interconnection requests to interconnect.

As noted in an April 2017 presentation to the NEPOOL Participants Committee, this proposal was favorably voted by the Transmission Committee on January 24, 2017 and by the Participants Committee on February 3, 2017.

The presumptive next step forward in New England's attempt to resolve the interconnection queue backlog by clustering studies would be that ISO-NE will file its tariff revisions with the FERC -- but the grid operator has signaled an intent to wait to file the revisions until there is "a high probability of a FERC quorum."  Three of the five seats on the Commission are presently vacant, and the Commission is currently operating without a quorum.  In the meanwhile, ISO New England's present tariff does not allow clustering of studies, so for now customers and others proposing to interconnect generation or transmission into the New England grid will continue to wait and push for reform.

Maine biomass resource RFP issued

The Maine Public Utilities Commission has issued an order approving a Request for Proposals for biomass energy resources.  At stake are two-year contracts through which biomass resources may sell energy and related products to Maine transmission and distribution utilities.

Earlier this year, the Maine legislature enacted An Act to Establish a Process for the Procurement of Biomass Resources.  Originally proposed as LD 1676 and enacted as Public Law 2015, Chapter 483, that law requires the Public Utilities Commission to initiate a competitive solicitation for 2-year contracts for up to 80 megawatts of biomass resources. 

By order dated June 17, 2016, the Commission approved a Request for Proposals pursuant to its authority under the Act.  The RFP document -- formally styled a Request for Proposals for the Sale of Energy from Biomass Resources -- was released at the same time. It asks for proposals from Biomass Resources for the sale of energy under one or more two-year contracts; bidders may also offer to sell capacity and/or renewable energy attributes as part of the contract.

The RFP defines a Biomass Resource as "a source of electrical generation fueled by wood, wood waste or landfill gas that produces energy delivered to the ISO-NE or NMISA region."  Additional requirements and criteria apply, including minimum capacity factor thresholds and preferences for creating in-state benefits.  It is possible that no contracts will be awarded, or that there won't be money to pay under those contracts.  If the Commission concludes that this solicitation is not competitive, based either on the solicitation process or the resulting bids, no bidders may be selected.  By law, payments are also contingent on the availability of funding for any above-market portion of the contracts, from a Cost Recovery Fund established by the Act.

Contract proposals are due on or before July 29, 2016. According to the Commission's materials, the RFP and all related documents and information will be available on the Commission's RFP website.

Record low prices in summer 2015 New England wholesale electricity market

The summer of 2015 brought New England the lowest wholesale electricity prices since 2003, thanks to record low prices for natural gas.  According to regional grid operator ISO New England Inc., this illustrates what happens "when New England power plants can access the vast supply of lower-priced, domestic natural gas being produced in the Marcellus shale deposit."

ISO-NE, "Summer 2015: The lowest natural gas and power prices since 2003"

In a post on its ISO Newswire site, the grid operator noted that the average real-time wholesale electricity price for June, July, and August 2015 was $26.86 per megawatt-hour (MWh). By comparison, the average real-time price of wholesale electric energy in 2014 was $63.32 per megawatt-hour.  While summer energy prices have typically averaged lower than winter prices in New England, 2015's summer prices were low even in comparison to other recent summers: $34.31 in 2014, or $43.94 in 2013.

What explains New England's low wholesale electricity prices this summer?  According to ISO New England, it's because existing natural gas-fired power plants could get fuel at a low price:

In essence, the reason was the low price of natural gas that could be delivered to the power plants that burn natural gas to make electricity. For most of the year, the price of natural gas is low in New England, and as a consequence, the demand for natural gas for both heating and power generation just continues to grow. In fact, in 2014, New England power generators using natural gas produced 44% of the region’s electricity.

The ISO-NE post describes how low-priced natural gas plus adequate interstate pipeline transportation capacity yields New England low electricity prices.  Indeed, the average price of  natural gas in New England during June, July, and August averaged a record low $2/MMBtu.  This is nearly 40% below last year's summer average ($3.27/MMBtu), itself the next-lowest summer record.

New England's average summer electricity price was even below that of other regions, like the Midwest.  According to ISO-NE, "This summer’s prices indicate that the region’s electricity prices can be competitive, in the more commonly understood sense, with other regions of the US when low-cost fuel is available." Indeed, at times the price of natural gas in New England was below that of the benchmark Henry Hub.

The post also describes how heavy winter demand for natural gas for both heating and power generation, combined with pipeline constraints, yields high natural gas prices and thus high electricity prices.  This has occurred repeatedly in recent winters, such as in January and February 2014 and February 2015.  What is at issue is thus the ability of the interstate natural gas pipeline transportation network to ship enough gas into the Northeast -- a capability exceeded through much of the recent winters, with the resulting price paid in coal and oil emissions as well as dollars.

As ISO-NE notes, most customers' retail rates for electricity are set using mechanisms to reduce rate volatility, and time of use rates are not yet widely adopted.  But the net movement of wholesale markets is eventually priced into retail rates.  Can New England keep competitive with other regions?