States to Hold Meetings on CPP Repeal

Posted on January 4, 2018 by Jessica Bell

Several states have recently announced that they will hold public meetings to discuss EPA’s proposal to repeal the Clean Power Plan.

  • The Delaware Department of Natural Resources and Environmental Control will host a listening session on January 8.  Registration information is available here.
  • The New York Attorney General and New York City Mayor, in partnership with several other groups, will host a people’s hearing on January 9, and will submit testimony to EPA.  Registration information is available here.
  • The Maryland General Assembly and Attorney General will hold a hearing on January 11.

EPA is accepting comment on the proposed repeal until January 16. EPA held one public hearing on the CPP repeal in West Virginia and has announced its plan to hold additional hearings.

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FERC Issues Twelfth Assessment of Demand Response and Advanced Metering

Posted on January 2, 2018 by Jeff Bayne

Last month, FERC issued its twelfth annual Assessment of Demand Response and Advanced Metering.  Under the Energy Policy Act of 2005, FERC is required to prepare and publish annual reports assessing the deployment of advanced meters and communications technologies, as well as the current state of demand response programs and their use in regional transmission planning.

Advanced meters, as defined by the U.S. Energy Information Administration, must measure and record usage data in, at minimum, hourly intervals and provide usage data at least daily to energy companies.  Using 2015 data, the most recent year available for advanced meters, FERC found that the number of advanced meters operational in the U.S. increased by over 6 million to a total of 64.7 million, which represents 42.9 percent of all meters nationwide.  Advanced meter deployment is relatively consistent across residential, commercial, and industrial customer classes.  However, there are significant regional differences, ranging from over 80 percent to under 10 percent.

In terms of demand response programs, FERC’s assessment found differences between programs at the retail and wholesale levels.  At the retail level, total potential peak demand savings from demand response programs increased 5.4 percent from 2014 to 2015, totaling 1,684 MW.  In contrast, in the organized wholesale markets demand resources’ contribution to meeting peak demand fell to 5.7 percent in 2016 from 6.6 percent in 2015.  The greatest decrease in demand resource participation was in the PJM Interconnection, L.L.C. region, although demand resource participation also fell in California Independent System Operator (CAISO), Independent System Operator New England, and New York Independent System Operator.

The final chapter of the report identifies regulatory barriers to improved customer participation in demand response, peak reduction, and critical period pricing programs.  Out of the barriers first identified in FERC’s 2009 National Assessment of Demand Response Potential, the December 2017 report identifies three as outstanding.  The first is implementing time-based pricing.  Although barriers to time-based pricing still exist, the report notes that in the past year several states have implemented time-based rate pilot programs.  The second barrier is that a lack of coordination between federal and state policies could slow the development of demand response resources.  However, the report adds that California has taken actions towards its goal of integrating all supply-side demand into CAISO wholesale markets by 2018.  Finally, the report addresses demand response as a distribution system resource.  It explains that demand response programs designed to meet bulk power system needs often have a limited ability to satisfy distribution system requirements, and that greater coordination between the operators of the distribution and bulk power systems may be necessary in order for demand response programs to be able to meet the needs of both.

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NERC’s 2017 Long Term Reliability Assessment Calls For Robust Planning in the Face of New Reliability Challenges

Posted on December 26, 2017 by Katherine O'Konski

Earlier this month, the North American Electric Reliability Corporation (NERC) released its 2017 Long-Term Reliability Assessment.  NERC’s long-term assessments, released annually, provide a high-level view of resource adequacy and identify long-term issues that will influence planning, development, and analysis of the bulk power system in the United States and Canada.  Pointing to retirements of conventional generation, the rapid addition of variable resources (e.g., wind and solar), a significant influx of natural gas generation, and tightening reserve margins in some areas, the assessment concludes that “[t]he electricity sector is undergoing significant and rapid change that presents new challenges for reliability,” and that more robust planning approaches are needed to ensure the bulk power system continues to be reliably operated.

The assessment finds that NERC-wide electricity peak demand and energy growth are at the lowest rates on record.  Simultaneously, conventional generation retirements have outpaced conventional generation additions.  Natural gas, wind, and solar continue to be rapidly added to the energy mix.  To address these challenges, the assessment provides policy recommendations for policymakers, industry, and itself.  Among its key recommendations:

  • FERC should support new market products and/or changes to market rules that support the provision of essential reliability services, including frequency response and increased system flexibility.
  • FERC should consider the reliability attributes of all generation to limit exposure to risk, and ensure that the generation resource mix continues evolving in a manner that maintains a reliable and resilient bulk power system.
  • All new resources should have the capability to support voltage and frequency.
  • Transmission planners and operators should report on expected reliability concerns related to interruptible natural gas transportation.
  • Where deregulated markets exist, market operators should develop additional rules and incentives to encourage increased fuel security, particularly during winter months.

A media release accompanying the assessment explains that “NERC will work with the industry on a comprehensive review of Reliability Standards to ensure compatibility with the changing resource mix and adequate levels of essential reliability services, including frequency response and increased system flexibility.”

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EPA Asks for Feedback on CPP Replacement Possibilities

Posted on December 21, 2017 by Jessica Bell

UPDATED 12.28.2017 The ANPRM has been published in the Federal Register and is available here.  Comments are due February 26, 2018.

EPA recently issued an advanced notice of proposed rulemaking (ANPRM) seeking information as it considers proposing emission guidelines to limit greenhouse gas emissions from existing electric utility generating units—that is, a rule to replace the Clean Power Plan. (The repeal of the CPP is underway, with EPA accepting comments through January 16, 2018.)

The ANPRM solicits comments on substantive issues that would be at the core of any new rule developed.  For example, EPA asks about the relative roles and responsibilities of states and EPA, as well as how to define the Best System of Emission Reduction and what sources would be covered by the rule.  EPA says that it welcomes comments on all related topics, although it asks that comments related to the repeal of the CPP be submitted in the separate docket.

Comments on the ANPRM will be due 60 days after it is published in the Federal Register.

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National Security Strategy Calls for an Embrace of Energy Dominance

Posted on December 19, 2017 by Jeff Bayne

Yesterday, the Trump Administration released its National Security Strategy of the United States of America.  The document identifies four vital national interests: “Protect the American People, the Homeland, and the American Way of Life”; “Promote American Prosperity”; “Preserve Peace through Strength”; and “Advance American Influence.”  The energy sector is addressed as part of “Promote American Prosperity,” and the National Security Strategy calls for an “Embrace of Energy Dominance.”

The energy-related section of this report defines energy dominance as “America’s central position in the global energy system as a leading producer, consumer, and innovator.”  According to the National Security Strategy, energy dominance “ensures that markets are free,” “U.S. infrastructure is resilient and secure,” and “access to energy is diversified,” while also “recogniz[ing] the importance of environmental stewardship.”  Coal, natural gas, petroleum, renewables, and nuclear are all part of the foundation for future growth envisioned in this report.

Unlike the last National Security Strategy issued by the Obama Administration, the Trump Administration’s strategy does not list climate change as a top strategic risk.  However, it does state that “[c]limate policies will continue to shape the global energy system,” adding that “U.S. leadership is indispensable to countering an anti-growth energy agenda that is detrimental to U.S. economic and energy security interests.”  It notes that the U.S. will remain a leader in reducing pollution, including greenhouse gases, but that the U.S. will do so through “innovation, technology breakthroughs, and energy efficiency gains, not from onerous regulation.”

The National Security Strategy goes on to outline five specific priority actions regarding energy:

  1. Reduce regulatory barriers;
  2. Promote exports of U.S. energy resources, technologies, and services;
  3. Ensure energy security, both by working with partners to protect against cyber and physical threats and by supporting the diversification of energy sources, supplies, and routes;
  4. Ensure universal access to affordable, reliable energy; and
  5. Improve the U.S.’s technological edge in energy, specifically nuclear technologies, battery storage, advance computing, carbon-capture technologies, and opportunities at the energy-water nexus.
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