FERC, DOE to hold Security Investments for Energy Infrastructure Technical Conference

The Federal Energy Regulatory Commission and the United States Department of Energy have scheduled a joint technical conference to discuss current cyber and physical security practices used to protect energy infrastructure and possible federal and state incentives for related security investments.

According to a notice issued on February 4, the Security Investments for Energy Infrastructure Technical Conference will be led by one or more FERC Commissioners and DOE senior officials. Its agenda addresses two high-level topics: types of current and emerging cyber and physical security threats, and how federal and state authorities can facilitate investments to improve the cyber and physical security of energy infrastructure.

In a supplemental notice issued on March 1, the agencies noted that the Commission has adopted a "well-developed set of mandatory and enforceable reliability standards that set baseline protections for both cyber and physical security of the bulk electric system" as well as "policies that allow for the recovery of prudently incurred costs to comply with those mandatory reliability standards." The supplemental notice describes the technical conference as aimed at better understanding:

1. the need for security investments that go beyond those measures already required by mandatory reliability standards, including in infrastructure not subject to those standards (e.g., natural gas pipelines);
2. how the costs of such investments are or could be recovered; and
3. whether additional incentives for making such investments are needed, and if so, how those incentives should be designed.

The supplemental notice describes two panels, the first of which will discuss types of cyber and physical security threats to energy infrastructure, particularly electric transmission, generation, and natural gas pipelines, as well as best practices for cyber and physical security mitigation beyond those measures already required by mandatory reliability standards and industry and government engagement needed to address these matters. The second panel will explore how federal and state authorities can provide incentives and cost recovery for security investments in energy infrastructure, particularly electric transmission, generation, and natural gas pipeline infrastructure

The federal agencies' Security Investments for Energy Infrastructure Technical Conference has been scheduled for on March 28, 2019.

FERC to hold session on state policies, wholesale markets

U.S. energy regulators have scheduled a two-day technical conference to consider how state energy policies affect wholesale electricity markets.

In a March 3 notice of technical conference, the Federal Energy Regulatory Commission gave public notice that it will hold a technical conference on May 1 and 2, 2017.  The notice describes tensions between competitive wholesale energy and capacity markets and state policies.  On the one hand, the Commission noted, "Competitive wholesale energy and capacity markets bring value to customers by efficiently pricing energy and capacity , taking into account the operational needs and the dynamics of the transmission system , and providing transparent signals for investment and retirement of resources."  Generally speaking, these wholesale competitive markets currently select resources based on principles of operational and economic efficiency without specific regard to resource type

But on the other hand, the Commission notes recent increases in "interest by state policy makers to pursue policies that prioritize certain resources or resource attributes" (such as renewable resources, or in-state resources).  That has led to what the Commission calls an "open question": "how the competitive wholesale markets, particularly in states or regions that restructured their retail electricity service, can select resources of interest to state policy makers while preserving the benefits of regional markets and economic resource selection." These topics have come up in discussions relating to several eastern regional transmission organizations and independent system operators, such as the IMAPP process in New England, and similar efforts in PJM and NYISO to consider the integration of public policy into markets.

To foster further FERC-level discussion about the development of regional solutions that "reconcile the competitive market framework with the increasing interest by states to support particular resources or resource attributes," the Commission has scheduled the May 1-2 technical conference. The notice specifically references a range in potential long-term expectations regarding the relative roles of wholesale markets and state policies in shaping the resource mix -- ranging from no state role on the one end, to state authority over resource selection that must be accounted for in wholesale market design -- and a variety of potential solutions in between.

Anyone who wishes to participate in the conference may submit a nomination form to FERC online by 5:00 p.m. on March 17, 2017. 

Electric storage resources technical conference set

U.S. energy regulators have scheduled a technical conference to discuss electric storage resources and how they could fit into the electric grid -- and how they might be compensated for doing so.  The Federal Energy Regulatory Commission will convene the discussion on November 9, 2016.

An electric storage resource is a facility that can receive electric energy from the grid and store it for later injection of electricity back to the grid.  Different projects might use different storage mediums -- for example, batteries, flywheels, or pumped hydropower.  A storage resource could be as small as a household battery, or as large as gigawatt-scale pumped storage. Projects could be interconnected in various ways -- such as to the transmission system, distribution system, or behind a customer meter -- and could serve different markets, ranging from regional transmission organizations and independent system operators, to transmission or distribution utilities, to customers or end users of electricity.

While each energy storage resource configuration offers its own different advantages and disadvantages from various perspectives, overall the Commission has noted that "storage resources may fit into one or more of the traditional asset functions of generation, transmission, and distribution."  In the Commission's Notice of Technical Conference, it expressed a desire "to explore the circumstances under which it may be appropriate for electric storage resources to provide multiple services, whether the RTO/ISO tariffs need to include provisions to accommodate these business models, and how the Commission may ensure just and reasonable compensation for these resources in the RTO/ISO markets."

The specific subject of the conference described in the Notice is "the utilization of electric storage resources as transmission assets compensated through transmission rates, for grid support services that are compensated in other ways, and for multiple services."  The Notice also sets up discussion of other issues including

(1) potential models for cost recovery for electric storage resources utilized as transmission assets, while also selling energy, capacity or ancillary services at wholesale;

(2) potential models to enable an electric storage resource to provide a compensated grid support service (like a generator providing  ancillary services under a reliability must-run contract) rather than being compensated for providing transmission service; and

(3) practical considerations for electric storage resources providing multiple services at once (i.e., providing both wholesale service(s) and retail and/or end-use service(s)). 

FERC will webcast and transcribe the conference, in addition to allowing in-person attendance.  The Commision directed those wishing to participate to submit a nomination form online by 5:00 p.m. on October 14, 2016.

Energy storage is attracting increased interest.  In another open docket, the Commission issued a series of data requests and a request for public comment in an effort to identify barriers to electric storage resources' participation in organized electricity markets in the U.S that could lead to unjust and unreasonable wholesale electricity rates.  In 2009, then-Chairman Wellinghoff testified before the Senate Committee on Energy and Natural Resources on the role of grid-scale energy storage as it relates to U.S. energy and climate goals, including its ability to integrate variable resources such as wind and solar into the grid.  Meanwhile, states too are pursuing storage opportunities.  A Massachusetts state energy office has issued a report finding that Massachusetts has the potential to develop for 600 MW of energy storage by 2025, which could lower costs, reduce carbon emissions, and improve grid reliability.

Generator interconnection technical conference scheduled

The Federal Energy Regulatory Commission has scheduled a technical conference to generator interconnection issues, including interconnection of energy storage.

The case has its origins in a 2015 petition to the Commission by the American Wind Energy Association, seeking a rulemaking to revise certain provisions of the Commission's pro forma Large Generator Interconnection Procedures (“GIP”) and pro forma Large Generator Interconnection Agreement (“GIA”).

AWEA is a national trade association representing a broad range of entities with a common interest in encouraging the expansion and facilitation of wind energy resources in the United States. Its members include wind energy facility developers, owners and operators, construction contractors, turbine manufacturers, component suppliers, financiers, researchers, utilities, marketers, customers, and their advocates.

In that petition, the trade group argued:

the time is ripe for the Commission to make certain regulatory and policy changes to interconnection procedures in order to remedy unduly discriminatory and unreasonable barriers to generator market access that inhibit the development of electric generation to meet the growing needs of electricity customers, and to facilitate the current dramatic transformation of the electric generation system (driven, in part, by Federal and State policies) in a timely, reliable and cost-effective manner.

AWEA's petition called for a variety of reforms to the interconnection procedures and agreement, particularly aimed at improving "(a) certainty in the study/restudy process; (b) transparency in the interconnection process; (c) certainty of network upgrade costs; and (d) accountability in the interconnection process."  After many comments were submitted on the rulemaking petition, AWEA asked the Commission to hold a technical conference as a forum for "open discussion" among interested parties.

The Commission has now issued notice of a technical conference to be held on May 13.  According to the notice:

The purpose of this conference is to discuss select issues related to a petition for rulemaking submitted by the American Wind Energy Association (Docket No. RM15-21-000). In addition, the conference will explore other generator interconnection issues, including interconnection of energy storage.

The notice also states that discussions at the conference may involve issues raised in other proceedings pending before the Commission, including without limitation 8 sets of specifically listed cases:

• E.ON Climate & Renewables North America LLC, Pioneer Trail Wind Farm, LLC, Settlers Trail Wind Farm, LLC v. Northern Indiana Public Service Company, Docket No. EL14-66-002;

• Entergy Arkansas, Inc., Docket No. ER14-671-000;

• Internal MISO Generators v. Midcontinent Independent System Operator, Inc., Docket No. EL15-99-000;

• Midcontinent Independent System Operator, Inc., Docket No. ER16-675-000;

• California Independent System Operator Corporation, Docket No. ER16-693-000;

• ISO New England, Inc., Docket No. ER16-946-000;

• Midcontinent Independent System Operator, Inc., Docket No. ER16-1120-000; and

• Midcontinent Independent System Operator, Inc., Docket No. ER16-1211-000. 

The conference will be held on May 13 at Commission headquarters in Washington, DC.

FERC considers geomagnetic disturbance standards

U.S. energy regulators examining reliability standards for the electric transmission grid relating to geomagnetic disturbances have scheduled a technical conference for March 1, 2016.

Geomagnetic disturbance, or GMD, events occur during solar storms when the sun emits charged particles whose magnetic field interacts with that of the Earth.  GMDs can affect transformers, transmission lines, and other electric grid infrastructure.  As the Federal Energy Regulatory Commission noted in its Order No. 779, "there is a general consensus that GMD events can cause wide-spread blackouts due to voltage instability and subsequent voltage collapse, thus disrupting the reliable operation of the Bulk-Power System."

In 2013, the FERC issued Order No. 779 directing NERC to propose Reliability Standards that address the impact of geomagnetic disturbances (GMD) on the reliable operation of the Bulk - Power System.  In 2015, NERC made its proposal, which the FERC has proposed to largely accept.

But the case before FERC, docketed as RM15-11, remains ongoing.  Grid operators, utilities, trade groups, and others have filed comments or otherwise participated in the case.

The Commission has now scheduled a GMD technical conference on March 1, 2016, as a forum for "a structured dialogue on GMD-related topics."  Items specifically identified for discussion at this stage include what kind of GMD event should be used as the "benchmark" for planning purposes, vulnerability assessments, and monitoring of related parameters.

FERC and EPA's Clean Power Plan

Following the U.S. Environmental Protection Agency's 2014 proposal to regulate carbon emissions from electric power plants and other major sources, federal energy regulators have scheduled a series of public technical conferences on how the Clean Power Plan may affect electric reliability, wholesale electric markets and operations, and energy infrastructure.

On June 2, 2014, the U.S. Environmental Protection Agency announced the Clean Power Plan, its proposed rule under Section 111(d) of the Clean Air Act to reduce carbon emissions from the nation's power plants.  Designed to reduce carbon emissions 30 percent below 2005 levels by 2030, EPA's proposal would impose limits on each state's rate of carbon emissions per megawatt-hour of electric energy generated.

The Federal Energy Regulatory Commission regulates the transmission and wholesale sales of electricity in interstate commerce, monitors energy markets, and protects the reliability of the high voltage interstate transmission system.  Acting out of concern over the possible impacts of the EPA Clean Power Plan on its regulated sector, on December 9, 2014, the Commission scheduled a series of technical conferences to develop public comment on these issues.

First, the Commission will hold a National Overview technical conference on February 19, 2015, at its Washington, DC headquarters.  Earlier this month, the Commission issued a supplemental notice describing the agenda for the National Overview.  After an introduction by EPA, the Commission expects to discuss:

• Electric reliability considerations: How will the Clean Power Plan affect electric reliability?  How can the U.S. sustain reliability as states and regions develop their plans to comply with the proposed carbon rule?  How could state, regional, and federal plans for compliance affect grid operations?  What tools are available to identify potential reliability impacts?  How can reliability planning processes and compliance planning efforts  coordinated to address potential issues?  What is the Commission's role in this area?
• Identifying and addressing infrastructure needs: What potential infrastructure needs may arise from various state or regional compliance approaches?  How can any infrastructure needs met in a timely manner in order to ensure system reliability?  How can relevant planning entities, industry, and states coordinate reliability and infrastructure planning and siting processes with state and/or regional environmental compliance efforts to ensure the adequate and timely development of new infrastructure?  Are additional mechanisms needed to ensure timely development of new infrastructure? Are adaptations to current Commission policies needed to facilitate the infrastructure needed for compliance with the proposed Clean Power Plan?
• Potential implications for Commission-jurisdictional markets:  How could potential compliance approaches to the proposed Clean Power Plan impact Commission-jurisdictional electric and natural gas markets?  What aspects, if any, of the wholesale and interstate markets would facilitate implementation of state or regional compliance plans?  What tools are available to address market issues as they arise?  What opportunities are available to coordinate compliance approaches with Commission-jurisdictional markets to meet the requirements of the proposed Clean Power Plan rule?

Following the National Overview, the Commission has scheduled three regional conferences in February and March 2015.

FERC plans conferences on EPA carbon rule impacts

If the U.S. Environmental Protection Agency's proposed carbon regulations for power plants are adopted, how will state and regional efforts to comply with the rule impact the electric power grid?  If states need new infrastructure like electric transmission lines or natural gas pipelines to comply with the EPA rule, what can be done to reduce regulatory barriers to new infrastructure development?

A fossil fuel-fired power plant near New York, NY.

The EPA's proposed Clean Power Plan rule would require states to meet customized standards for how much carbon dioxide their electric power sector emits per unit of useful energy.  As envisioned by EPA, each state can choose its own path to meeting these standards by combining elements from a menu of four "building blocks": better coal plant efficiency, increased utilization of natural gas plants, increased renewable energy, and increased energy efficiency.

The implications of different approaches to complying with the proposed rule will be the focus of an upcoming series of technical conferences to be held by the Federal Energy Regulatory Commission.  According to the Commission's public notice, state, regional and/or federal plans for compliance with the proposed Clean Power Plan may impact Commission-jurisdictional markets, grid operations, and infrastructure.  The series of technical conferences is designed to provide forums for identifying issues and solutions.  The Commission also plans to provide an opportunity to discuss how compliance scenarios may impact existing infrastructure and drive the need for additional infrastructure, especially new electric transmission and natural gas pipeline facilities, and whether there are regulatory barriers that need to be addressed, and by whom, to ensure the timely development of those facilities.

The conferences will begin with a Commission-led National Overview session at FERC headquarters on February 19, 2015.  The National Overview will address whether regulators and industry have the appropriate tools to identify any reliability or market issues that may arise, potential strategies for compliance with the EPA regulations and coordination with FERC-jurisdictional wholesale and interstate markets, and how to coordinate reliability and infrastructure planning processes with state and/or regional environmental compliance efforts to ensure the adequate development of new infrastructure and to manage any potential reliability and operational impacts of proposed compliance plans. The Commission will offer a live webcast of the National Overview, which will be archived for three months.

Following the National Overview technical conference, the Commission will hold three regional technical conferences, on dates to be announced, in Washington, DC, St. Louis, MO, and Denver, CO.  Each regional event will include discussion of the specific potential impacts to regional reliability, power system operations and generator dispatch, and needed infrastructure upgrades.

Will the EPA's Clean Power Plan be finalized and take effect?  If so, when -- and in what form?  Federal carbon emission limits are as yet untested in the U.S., and other innovative regulatory efforts have met with years or even decades of delay before taking effect.  At the same time, the prospect of federal carbon rules affecting the electric power sector spurs energy regulators to take a serious look at potential impacts of the carbon rules, and to begin planning for their possible future effectiveness.