Regional grid operators, including the one in Texas, have begun letting federal regulators know their views on a number of resilience-related issues in response to a review launched in early January.
Regional transmission organizations and independent system operators had until the end of the day March 9 to submit comments to the Federal Energy Regulatory Commission in the proceeding. The agency's investigation is aimed at identifying possible resilience and reliability concerns as the bulk power system shifts more toward natural gas-fired and renewable energy and becomes less reliant on coal-fired and nuclear generation.
The commission kicked off the inquiry after rejecting a proposal from the U.S. Department of Energy aimed at avoiding future coal-fired and nuclear power plant retirements in a bid to bolster reliability. The DOE asked FERC in September 2017 to craft a rule requiring grid operators to ensure that certain plants with at least 90 days of fuel on-site can recover all their costs plus a return on investment. The proposal largely would have benefited coal-fired and nuclear generating facilities capable of nearby fuel storage.
FERC later rejected the proposal, saying the DOE failed to demonstrate a reliability threat from rising coal and nuclear retirements. But the commission initiated a new proceeding to seek input from grid operators on their resilience concerns.
The filings of the Midcontinent ISO, ISO New England, PJM Interconnection and the Electric Reliability Council of Texas were among the first to be made public late in the day March 9. Those documents addressed a wide variety of topics, including how resilience should be defined, actions the grid operators are taking to assess and mitigate resilience risks, and what more FERC could be doing to help them enhance system resilience.
An initial quick review of the filings showed that PJM is calling for nationwide coordination of the method to be used to determine critical loads and the development of criteria to ensure that dual-fuel units can serve those loads. MISO urged FERC to support more effective interregional operations to better address potential threats to grid resilience.
For its part, the ISO-NE said it already is taking steps to mitigate its region's most significant resilience challenge — the possible lack of generating fuel, particularly in winter, against the backdrop of coal, oil and nuclear unit retirements, constrained fuel infrastructure, and the difficulty in permitting and operating dual-fuel generating capability.
ERCOT, jointly with the Public Utility Commission of Texas, chimed in even though it did not need to because it is not subject to FERC's jurisdiction. However, the grid operator and state regulator said they were doing so because the outcome of the proceeding could impact the potential development of reliability standards that would govern the conduct of ERCOT and its users, owners and operators of the bulk-power system. They also assured FERC that ERCOT has robust processes in place to ensure that its system will be operated in a way that can resist and recover from a variety of foreseeable disturbances, and those processes "will continue to identify other areas for improvement as the system evolves."
S&P Global Market Intelligence will offer a more in-depth look at the filings in a subsequent story. (FERC docket AD18-7)
