Groups Urge Risk-Based Approach for Covered Entities for Cyber Incident Reporting
November 10, 2022
by Paul Ciampoli
APPA News Director
November 10, 2022
The Department of Homeland Security’s (DHS) Cybersecurity and Infrastructure Security Agency (CISA) should define “covered entities” for cyber incident reporting in a risk-based manner, the American Public Power Association (APPA) and the Large Public Power Council (LPPC) said in response to a request for information (RFI) issued by CISA on the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (CIRCIA).
“While the whole electric sector is critical to national and economic security, not all electric utilities have the same risk profile,” APPA and LPPC said in their comments.
“Acknowledgement of this fact is of particular importance to public power utilities, as APPA’s and LPPC’s members have widely different risk profiles ranging from an electric utility with transmission assets that serves millions of customers to a very small distribution electric utility without an industrial control system serving 200 customers,” they said.
Moreover, APPA and LPPC strongly encouraged CISA to utilize previous efforts to identify the most critical of critical systems and assets as it determines what constitutes a covered entity under the law.
APPA and LPPC believe that such a targeted definition of “covered entity” — especially in this initial implementation period — has the dual benefit of ensuring that entities with the highest risk profiles begin incident reporting immediately, thereby increasing national security, and keeping the number of entities covered under the law to a limited, more manageable level, allowing CISA and industry to more easily work out any implementation kinks.
APPA and LPPC also recommended that CISA tightly limit the definition of “covered cyber incident” to significant and substantial incidents that impact critical systems or services.
For example, a large electric utility that is a covered entity should have to report if it discovers an industrial control system breach at a generation plant or transmission facility. “A covered entity should not have to report a phishing attempt on the email of an accountant that has no connection or control of the operating technology for the electric system,” APPA and LPPC said.
“Critical infrastructure entities are the targets of malicious cyber actors millions of times a day. An overly broad definition of covered cyber incidents would present enormous compliance challenges for utilities, and even if these challenges could be overcome, the result would be a deluge of reports that would make it difficult, if not impossible, for CISA to determine a signal through the noise.”
Balancing Situational Awareness and Cyber Incident Response
The groups also argued that as CISA considers reporting processes and reporting content, it is important that it considers the ultimate purpose of this reporting, which is not to over burden victims for the sake of reporting, but to assist critical infrastructure and the federal government in identifying, addressing, or responding to cyber security threats.
Some critical infrastructure sectors are already covered by federal mandatory reporting of certain cyber incidents, in addition to state laws for reporting of data breach incidents. “In implementing CIRCIA’s incident reporting standards, APPA and LPPC strongly encourage DHS CISA to harmonize any new obligations with utilities’ existing requirements to avoid confusion and conflict between CIRCIA obligations and other mandatory reporting channels.”
Additionally, some sectors, like the electric sector, also have active voluntary reporting and machine-to-machine sharing already taking place. “CISA should recognize and take into consideration these voluntary reporting pathways and associated sector focused analysis, given the value these mechanisms currently provide to critical infrastructures.”
Existing Reporting
A covered entity is exempt from reporting under CIRCIA if it is already required to make reports on similar information to another federal agency, within a similar timeframe, if there is an agreement in place between CISA and that other federal agency, the groups pointed out.
Given the existing incident reporting regimes overseen by the Federal Energy Regulatory Commission and the Department of Energy, “CISA should engage in direct and deep consultation with FERC and DOE as it works to implement CIRCIA.”
Moreover, CISA must take into account existing data breach reporting requirements at the state level, they added.
“To improve the threat landscape and associated awareness of it, it will be critical to work with existing infrastructures wherever possible to allow single-point reporting with the government being responsible for sharing information internally in a need-to-know environment, rather than imposing multiple reporting obligations on an impacted entity, which may also be dealing with a live cybersecurity event.”
Cost Impacts
APPA and LPPC also said that CISA must be mindful of the cost of any new rule on smaller entities.
“The cost of electric service is a key factor in the nation’s economic health, and the reality of varying, but finite resources and budgets suggests that overspending on security measures may compromise grid reliability in other respects. This is especially important to consumer-owned, not-for-profit public power utilities,” they said.
Snohomish County PUD Marks Completion of Microgrid and Clean Energy Center
November 10, 2022
by Paul Ciampoli
APPA News Director
November 10, 2022
Washington State’s Snohomish County PUD recently hosted a ribbon-cutting to celebrate the completion of its Arlington Microgrid and Clean Energy Center.
The project is located near the Arlington Airport and demonstrates multiple uses of energy storage, including utility-scale battery energy storage, residential battery energy storage and vehicle-to-grid charging systems.
The PUD’s Arlington Microgrid is a combination of a 500-kilowatt solar array, 1-megawatt/1.4-megawatt-hour lithium-ion battery energy storage system and a pair of vehicle-to-grid charging stations. The group of interconnected loads and distributed energy resources focus on disaster recovery, grid resiliency and electric vehicle integration.
Washington’s Department of Commerce Managing Director Jennifer Grove stressed the importance of collaborating with forward-thinking utilities like the PUD in her remarks. The PUD received $3.5 million in funding from the Department of Commerce’s Clean Energy Fund.
Other attendees included U.S. Congresswoman Suzan DelBene, state Senator June Robinson, and Representatives Keith Goehner, Mike Steele and Carolyn Eslick, and members of the Arlington City Council.
John Haarlow, PUD CEO/General Manager, spoke about the project’s connection to the future and how the PUD is working to better understand new technology.
“The lessons the PUD is learning at this project every day are informing our future,” said Haarlow. “Battery energy storage will help make critical infrastructure impervious to outages and help us meet energy demand when customer usage is at its highest. Vehicle-to-grid charging will allow us to work with homeowners and business owners to leverage EVs as backup or grid-assisted power sources.”
The Arlington Microgrid was designed and sized to provide power to the Clean Energy Center and a future community office, which is currently under construction on the site, during an outage that could be caused by a major windstorm or earthquake.
PUD Generation Engineer Scott Gibson, who oversaw the Arlington Microgrid project, and Hitachi Energy General Manager of Grid Edge Solutions Antonio Verga both spoke on the complexity of the project and the key to collaboration between the PUD and the numerous vendors.
“The Arlington Microgrid provides a foundation for meeting both today’s emerging energy challenges and the future energy needs in Washington state and beyond,” said Verga.
One of the most impressive aspects of the project is the ability for the microgrid to disconnect from the electrical grid and transition to microgrid mode seamlessly, the PUD said.
“At most microgrids, the disconnection from the larger grid to microgrid mode is very noticeable and can result in a momentary power interruption lasting several seconds,” said Gibson. “At the Arlington Microgrid this transition is not noticeable to the eye or even the PUD’s metering equipment and has no effect on computer systems running in the Clean Energy Center. This is a significant achievement.”
The PUD plans to use the Clean Energy Center and accompanying solar tree to demonstrate microgrid technology and educate the public about battery energy storage and vehicle-to-grid technology.
For more on the Arlington Microgrid and Clean Energy Center, visit snopud.com/microgrid.
Public Power Utility Crews Deploy to Help with Florida Power Restoration Efforts
November 9, 2022
by Paul Ciampoli
APPA News Director
November 9, 2022
Crews from public power utilities on Nov. 9 traveled to various locations in Florida prior to the arrival of Tropical Storm Nicole, which is expected to turn into a hurricane.
Amy Zubaly, Executive Director of the Florida Municipal Electric Association (FMEA), on Nov. 8 said that FMEA and its members were closely watching and monitoring Nicole.
Florida public power utility Keys Energy Services (KEYS) on Nov. 9 said it had mobilized six linemen to assist with post-Hurricane Nicole power restoration efforts in Ft. Pierce, Florida.
KEYS’ crew will assist personnel from other regional utilities and contractors with regional power restoration in the aftermath of the storm.
KEYS’ linemen, along with three bucket trucks, one digger truck, one material trailer, and one utility pole trailer, departed for Ft. Pierce on Wednesday, November 9, and will be pre-staged to begin assisting with power restoration once the storm has passed.
“Our crew is looking forward to lending their unique hurricane restoration experience to Fort Pierce Utilities Authority, a fellow public power utility,” said Lynne Tejeda, KEYS’ General Manager & CEO.
Also on Nov. 9, Louisiana public power utility Lafayette Utilities System (LUS) reported that LUS line crews headed out early that morning to travel to Tallahassee, Fla., a public power city, ahead of Tropical Storm Nicole. “LUS crews will ride out the storm with the Tallahassee crews and will assist in restoration once weather conditions are safe,” LUS said in a tweet.
Meanwhile, crews from Alabama public power utility on Nov. 9 headed out for Ocala, Fla., to arrive in advance of Nicole and be ready to work as soon as weather permits.
Another Alabama public power utility, Riviera Utilities, reported that 14 of its linemen and two engineering technicians on Nov. 9 departed for Gainesville, Fla., a public power city. “Our mutual aid crews will be on-site and ready to help once Nicole makes landfall,” Riviera Utilities said.
“Tropical Storm Nicole continued to strengthen as it swirled across the western Atlantic from Tuesday to Wednesday, and AccuWeather meteorologists said the massive storm will make landfall as a Category 1 hurricane along Florida’s east coast early Thursday morning,” AccuWeather reported on Nov. 9.
SMUD to Collaborate with Japan’s TEPCO on Vehicle-Grid Integration Technologies
November 9, 2022
by Paul Ciampoli
APPA News Director
November 9, 2022
California public power utility SMUD and the Tokyo Electric Power Company Holdings (TEPCO), Japan’s largest electric utility, on Nov. 2 announced an agreement to collaborate on vehicle-grid integration technologies with the purpose of accelerating transportation electrification and decarbonization.
The Memorandum of Understanding between SMUD and TEPCO establishes a framework for shared research and collaboration on how to expand and support EV adoption and vehicle-to-everything technology while maintaining a resilient and reliable power grid.
The collaboration also aims to enhance solar consumption initiatives, reduce on-peak load, prevent strain on distribution infrastructure, increase customer bill savings and share the grid value of these services with customers.
With respect to grid planning, operations, interconnection and utility and customer financial impacts, SMUD and TEPCO will study, develop and pilot complementary programs that further account for, and promote, vehicle-grid integration technologies.
Automated EV load management, managed EV charging, bidirectional EV charging and other advanced grid services also grant customers access to backup power resources for their homes or businesses and Virtual Power Plant technology for battery aggregation in a manner that bolsters grid stability and systemwide decarbonization, TEPCO said in a news release.
Salt River Project’s Mike Hummel to Retire as General Manager
November 8, 2022
by Paul Ciampoli
APPA News Director
November 8, 2022
On Nov. 7, Mike Hummel announced to the Salt River Project (SRP) Board of Directors that he will be retiring from SRP in May 2023.
“As Hummel approaches his fifth year as general manager, he decided the time was right to retire after nearly 41 years of dedication to SRP’s mission, its customers and the Arizona community,” SRP said.
The SRP Board will conduct a search to fill his role with support from executive search firm Korn Ferry.
The Board expects to identify a new general manager before Hummel retires in May.
Public Power Utilities Prepare for Arrival of Tropical Storm Nicole
November 8, 2022
by Paul Ciampoli
APPA News Director
November 8, 2022
Public power utilities are preparing for the arrival this week of Tropical Storm Nicole, which is expected to turn into a hurricane.
Amy Zubaly, Executive Director of the Florida Municipal Electric Association (FMEA), on Nov. 8 said that FMEA and its members were closely watching and monitoring Nicole.
“Like all storms, the where and when landfall will occur is still a fluid situation, but Nicole is likely to make landfall along the central to south-central east coast of Florida,” she said.
Zubaly said that FMEA has been in communication with all of Florida’s public power communities to discuss anticipated needs in advance of and following the storm.
“In addition, we have been in touch with our mutual aid partners across the southeast,” she noted.
Zubaly said that crews from Lafayette, La., Alabama, Paducah, Ky., and Keys Energy, Fla., were being pre-staged in various Florida public power utilities in advance of the storm, “and several others on standby to come in post storm, once conditions are safe and depending on Florida public power’s needs.”
Florida public power utility Kissimmee Utility Authority said it has activated its Emergency Operations Plan.
The utility is currently operating at Alert Level 3 and will advance to Alert Level 4 once the storm is within 24 hours of impacting its 85-square-mile service territory in Osceola County. Once the storm passes, its crews will begin their damage assessment analysis to determine if additional assistance is needed.
“Nicole may be capable of causing power outages and flooding. In addition, restoration may be hampered by flooding, downed trees, high winds, or other obstacles. KUA crews are prepared to work long hours after the storm passes, restoring service to customers as quickly and as safely as possible,” KUA said.
Meanwhile, South Carolina’s Santee Cooper on Nov. 8 said its team members were making preparations for the anticipated effects that Tropical Storm Nicole may have on Santee Cooper’s service territory.
As of noon on Nov. 8, Santee Cooper went to Operating Condition (OpCon) 4 alert status. This means there is a possible threat to Santee Cooper’s electric system, but effects may be limited or uncertain.
At OpCon 4, the utility is primarily checking and fueling vehicles, including line trucks, making sure communications equipment is in proper working order and taking inventory and procuring supplies as needed, such as utility poles, electric transformers and associated equipment.
A hurricane warning was issued along the central part of Florida’s east coast on Nov. 8 as Tropical Storm Nicole “churned across the Atlantic and showed signs of further strengthening as it tracked toward” the state, AccuWeather reported. AccuWeather “meteorologists expect this sprawling storm to take a turn and hit Florida’s east coast — as a hurricane — later this week before it takes a run up the Eastern Seaboard.”
Sunrun to Build and Operate Puerto Rico’s First Virtual Power Plant
November 8, 2022
by Paul Ciampoli
APPA News Director
November 8, 2022
Sunrun has been selected by Puerto Rico’s electric utility provider to develop a 17-megawatt virtual power plant (VPP), the first distributed large-scale storage program on the island.
The Governing Board of the Puerto Rico Electric Power Authority, a public power utility, approved the terms of the agreement on October 26, 2022. The agreement is subject to regulatory sign-off by the Puerto Rico Energy Bureau and the Fiscal Oversight Management Board.
Sunrun will spend the next year enrolling customers into the program and begin networked dispatches in 2024.
“Customers will benefit from the cost savings of on-site energy generation and backup power and will also be compensated in exchange for strategically sharing their stored energy with Puerto Rico’s power grid, creating a shared clean energy economy,” it said.
Batteries enrolled in the VPP will continue maintaining adequate backup reserves to power through potential grid outages at participants’ homes. All customers with batteries are also eligible to enroll and can opt out at any point during the 10-year program.
In 2019, two years after Hurricane Maria dismantled the island’s electric grid, the Puerto Rico Energy Public Policy Act was passed by the Legislature to set the parameters for a forward-looking energy system that maximizes distributed generation.
The Puerto Rico Energy Bureau (PREB) determined that VPPs were key to achieving the legislation’s goals of building a resilient and robust energy system and meeting Puerto Rico’s renewable portfolio standards, Sunrun said.
Burbank Water and Power Enters Agreement for First Utility-Scale Battery Storage Project
November 8, 2022
by Paul Ciampoli
APPA News Director
November 8, 2022
ESS Inc. and California public power utility Burbank Water and Power (BWP) have entered into an agreement for ESS to deliver BWP’s first utility-scale battery storage project.
Under the agreement, a 75 kilowatt (kW)/500 kilowatt hour kWh ESS “Energy Warehouse” will be installed and connected to a 265 kW solar array on BWP’s EcoCampus.
The iron flow battery will support the increased use of renewable power and allow excess renewable energy to be stored and used as baseload energy for Burbank, improving the resilience and reliability of the grid, ESS said on Nov. 4.
“BWP is already using small-scale battery technology at our substations, but we see the value in adding considerably more storage to the network. This initiative will be the largest battery installed in Burbank, providing enough renewable power for 300 homes annually,” said Mandip Samra, Assistant General Manager for Power Supply at BWP, in a statement. “The project is a big step forward to help meet our goal of having a greenhouse gas-free power supply by 2040 and providing energy storage for Burbank now and for decades to come.”
The storage system is expected to be installed in Burbank by December 2023.
In September 2022, another California public power utility, SMUD, and ESS Inc. announced an agreement to provide up to 200 megawatts/2 gigawatt-hours of long duration energy storage that will be provided by ESS.
APPA Weighs in on Energy Tax Provisions of Inflation Reduction Act
November 7, 2022
by Paul Ciampoli
APPA News Director
November 7, 2022
In comments filed with the Internal Revenue Service (IRS) and the Treasury Department on Nov. 4 related to the implementation of the Inflation Reduction Act, the American Public Power Association (APPA) weighed in on several key issues tied to the energy tax provisions of the IRA.
Tax-Exempt Bond Financing
A number of IRA sections include a reduction in the respective credit for tax-exempt bond financing.
APPA addressed the question of what additional guidance would be helpful in determining how to calculate the reduction.
APPA said that further clarification is needed to help in determining how to calculate the reduction.
The first clarification relates to the allocation of bond proceeds to qualifying facility costs for purposes of investment tax credits (ITCs).
Qualifying facility projects likely will be quite complicated and include elements that qualify as basis for an ITC and elements that will not, APPA said.
“We respectfully request that Treasury allow a project owner to use the same cost allocation rules for purposes of determining what aspects of a project are financed with tax-exempt debt, thereby applying them with regard to the calculation of any reduction under 26 USC 45(b)(3) or other comparable provisions applying to other energy tax credits.”
The second clarification relates to pledges of tax credit direct payments.
In financing a qualifying facility, a project owner may issue debt that pledges direct payment proceeds to the payment of principal and/or interest on that debt. Insofar as that debt meets the requirements of Internal Revenue Code (IRC) section 103, interest paid on that debt would be exempt from federal tax. In turn, IRC section 149(b) provides, in part, that the requirements of IRC section 103 are not met if the debt is “federally guaranteed.”
APPA believes that a decision to pledge direct payment credits to the payment of principal and/or interest should not constitute a federal guarantee. The reduction in credits for tax-exempt bond financing provided under IRC sections 45(b)(3), 48(a)(4), 45Y(g)(8), 48E(d)(2) “clearly indicate Congress’ intent to allow for the tax-exempt financing of tax-creditable facilities.”
The manner in which the owner of the facility and issuer of debt chooses to use the direct payment credit does not change this intent. “As such, Treasury and IRS should make clear that pledging direct payment proceeds to the payment of principal and/or interest on debt does not constitute a federal guarantee of that debt for purposes of IRC section 149,” APPA argued.
Investment Credit Facility
APPA also responded to the question of whether guidance is needed to determine whether an investment credit facility that elects to claim the Section 48 investment tax credit in lieu of the Section 45 production tax credit is subject to all of the requirements of Section 45, including the requirement that electricity generated by the investment credit facility be sold to an unrelated person.
“APPA strongly believes that IRC section 45 should not include a requirement that electricity generated by an investment credit facility be sold to an unrelated person, at least as far as state and local entities, including public power utilities, are concerned.”
One of the key purposes of making tax credits available by direct payment to state and local entities is to encourage ownership of such facilities, APPA said.
“Direct ownership will allow more of the value of these tax credits to be used to reduce project costs – and so result in lower rates to consumers – or used to make further grid investments. Both would be helpful in meeting the IRA’s clean energy and climate goals,” APPA said.
“Direct ownership also means local jobs, for local generation, under local control. One role of these facilities will be to power local facilities, such as town halls, police departments, fire departments, convention centers, traffic lights, rapid transit, and the like.”
Requiring that power be sold to an unrelated person for purposes of an ITC would preclude a governmental entity from owning qualifying facilities, and thus require them to rely on power purchase agreements to serve its own electric power needs, APPA said.
“Likewise, one of the IRA’s goals is to promote energy security by encouraging entities to pair generation with storage and the appropriate switching equipment to create renewably powered microgrids. Each of these investments is encouraged through tax credits under the IRA, and the concept of independent and energy secure microgrids occurred throughout the development of this legislation.”
However, if an unrelated party rule were imposed and if a municipality wanted to create such a microgrid to service a related governmental entity, it would be required to contract with an outside contractor to own these facilities to qualify for these tax credits. In other words, a municipality would have to privatize such a microgrid for the related grid, generation, and storage to qualify for a tax credit, APPA said.
“This is a perverse outcome that would be contrary to the fundamental purpose of the underlying statute and to the purpose of the direct pay provisions.”
Congress “had years in which to amend draft legislation to extend the PTC’s unrelated party rule to the ITC, and yet there is no indication Congress ever intended to do so. APPA would strongly urge Treasury and IRS not to extend the unrelated party rules to the ITC.”
Nuclear Power Production Credit
APPA also addressed a question related to the IRA’s addition of a zero-emission nuclear power production credit.
Section 45U(a)(2) reduces the amount of the Section 45U credit by a “reduction amount” that is calculated, in part, based on the gross receipts from any electricity produced by the facility. Section 45U(b)(2)(B) provides that gross receipts generally include any amount received by a qualified facility that are from a zero-emission credit program unless an exclusion applies.
APPA responded to the question of whether guidance is needed to clarify the meaning of the term “gross receipts,” especially as it applies to taxpayers receiving revenue through cost-of-service regulation or regulated contracts and who do not sell electricity in a manner attributable to individual nuclear reactors such as through sales into organized electricity markets or via power purchase agreements to third parties.
“Any definition of gross receipts should apply equally across entities claiming the new zero-emission nuclear power production credit, regardless of the ownership of such entities,” APPA said.
For example, if taxable entities are allowed to deduct depreciation and other cost against revenue for purposes of calculating gross receipts, tax-exempt entities should be treated the same for purposes of calculating the new credit, APPA said.
“Failing to do this would mean that owners in similar circumstances, or even co-owners of the same facility, could qualify for differing levels of credits or even have one owner qualifying for a credit and another owner qualifying for no credit at all. This would be inequitable and would also work against the purpose of the provision, which is to encourage the continued operation of these facilities,” APPA argued.
Along with these topics, APPA also weighed in on a number of other areas related to the IRA.
CAISO Touts Successes During Heat Wave, Details Areas For Improvement
November 6, 2022
by Peter Maloney
APPA News
November 6, 2022
A new report from the California Independent System Operator (CAISO) details the successes and failures of the system’s electric grid during the record heat wave at the end of the summer.
From Aug. 31 through Sept. 9, California, and much of the West, experienced 10 days of triple-digit heat with only minimal nighttime cooling and record electricity use. On Sept. 6, record temperatures were set all over California and the West and demand on the CAISO system reached a record peak of 52,061 megawatts (MW). During that time, CAISO issued Flex Alerts calling for voluntary consumer conservation for a record 10 consecutive days.
During the heat wave event, CAISO’s daily average prices rose to $600 per megawatt hour (MWh) with maximum prices reaching $2,000/MWh in the real-time market. Day-ahead average prices reached $300/MWh.
Despite the intense heat, CAISO “was able to keep electricity flowing without interruption thanks to increased capacity added under California’s resource adequacy program, new state programs that provided non-market resources to address extreme events, enhanced collaboration with state and federal agencies and significant conservation by commercial and residential electricity customers,” the ISO said in its Summer Market Performance Report Sept 2022.
The report also cited needed market enhancements to improve how increasingly frequent, extreme, and long heat events are managed, including the clearing of energy exports in the market and real-time testing for resource sufficiency. In particular, the report identified needed software improvements, especially for the clearing of exports and the resource sufficiency test used in the Western Energy Imbalance Market (WEIM).
CAISO credited several factors to the fact that electricity kept flowing during the heat wave and it did not have to call for rotating outages, including increased capacity through resource adequacy procurement since summer 2020, including more than 3,500 MW of lithium-ion battery storage.
CAISO also credited market enhancements, including clarification of scheduling priorities, enhancements to resource sufficiency evaluations and electricity market pricing designed to incentivize generation during periods of high demand.
CAISO noted, however, that demand during the heat wave “far exceeded” the 49,748 MW of resource adequacy shown to the ISO and, thus, was “insufficient” to cover peak demand during some periods.
To fill the gap, CAISO called on up 1,300 MW of demand response, comprised of 500 MW of voluntary demand response bid in the market and 800 MW of emergency demand response.
Regional resources and coordination were also a factor. CAISO called on 6,500 MW of imports from outside its system during the height of the heat wave, as well as 1,000 MW from WEIM.
Among the non-market resources that helped keep the lights on during the heat wave, CAISO said they ranged from non-market demand response, to behind-the-meter backup diesel generators, and temporary grid-side natural gas-fired resources that were deployed by utilities and state agencies with coordination from a wide variety of government, utility, and customer and business groups.
In terms of improvements, CAISO recommended changes that would ensure that energy storage resources are appropriately charged and accounted for in ISO systems to avoid manual corrective action, which happened during the event.
CAISO identified a software issue that resulted in storage resources not charging sufficiently early in the day. Specifically, storage resources that bid above $150/MWh to charge were not charged by the market. “The high prices experienced during the heat wave presented new scenarios for the ISO to learn about the complexities and challenges of managing battery state of charge,” the report said.
During the stresses created by the heat wave, CAISO also discovered there was both over- and under-counting of capacity available to the ISO in the WEIM resource sufficiency evaluation.
If a balancing authority fails the resource sufficiency evaluation, transfers into it from other WEIM participants are limited until the insufficiency is resolved.
On Sept. 6, the ISO failed the resource sufficiency evaluation in two instances, and transfers into the ISO were limited, but not material because the limits were well above the actual available transfers of 1,000 MW from the WEIM.
Upon further investigation, CAISO found that there was both over- and under-counting of capacity, the net impact of which would have potentially led the ISO to fail the resource sufficiency evaluation up to an additional four instances.
CAISO said it has “already addressed some of these issues” and is “evaluating fixes or potential enhancements for the others.”
CAISO has scheduled a stakeholder call for Nov. 17 to review details of the analysis and answer stakeholder questions.
CMUA Responds to Report’s Findings
In response to the report’s findings, Barry Moline, executive director of the California Municipal Utilities Association (CMUA), said that “Preparing for such an event this summer, publicly owned electric utilities and water agencies coordinated closely with the Governor’s Office, California Energy Commission, and the California Independent System Operator. We worked diligently to locate, confirm and generate firm power with every available back-up generator; facilitated customer conservation at key times; and pushed existing power supply to its limit. Only by working together did we avoid major disruption.”
Moline said that going forward, “publicly owned electric utility and water and wastewater agencies will continue to coordinate closely with the Administration and CAISO to decarbonize while assuring that California has the infrastructure and power supply it needs to provide affordable and continuous power.”