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SMUD, EPRI Launch Pollinator Project at Former Nuclear Power Site

January 3, 2023

by Peter Maloney
APPA News
January 3, 2023

The Sacramento Municipal Utility District (SMUD) and the Electric Power Research Institute (EPRI) recently launched a project to restore prairie land and pollinator habitat on a portion of land at the site of a former nuclear power plant.

The SMUD Rancho Seco Restorative Energy Project is at the 2,000-acre site of the Rancho Seco nuclear plant that was decommissioned in 1989 and is part of native tribes’ ancestral lands. It is now used for public recreation, an endangered species conservation bank, a sanctuary for rescued wildlife and is home of the 1,000-megawatt (MW) gas-fired Cosumnes power plant and a utility-scale solar power project, as well as the federally protected California Tiger Salamander.

The restoration project aims to create a pollinator habitat under solar arrays and along other portions of 20 acres of land at the Rancho Seco site in Sacramento County, Calif. The project will measure changes in energy, soil carbon, and management costs. Expected outcomes include the establishment of native plant species promoting pollinator habitats, EPRI said.

“Successful demonstration could provide the blueprint for future renewable energy projects throughout the country that are restorative not just in their kilowatts, but also for local people and biodiversity,” Jessica Fox, senior technical executive and conservation biologist at EPRI, said in a statement.

Collaborators in the four-year, multi-phase Restorative Energy Project include the University of California, Davis, the Xerces Society for Invertebrate Conservation, D.E. Shaw Renewable Investments, and NovaSource Power.

SMUD is part of EPRI’s Power-In-Pollinators initiative, which was launched in 2018 and is the largest collaboration of power companies in North America working to understand pollinators.

In addition to SMUD, several other public power utilities across the country are engaged in efforts to improve pollinator habitats, including Bonneville Power Administration, City Utilities of Springfield in Missouri, Lincoln Electric System in Nebraska, Logansport Municipal Utilities in Indiana, Los Angeles Department of Water and Power, Nebraska Public Power District, New York Power Authority, Omaha Public Power District, Southern Minnesota Municipal Power Agency, Vermont Public Power Supply Authority, and Salt River Project.

California Grid Operator Adopts Policies to Support Grid Reliability

January 3, 2023

by APPA News
January 3, 2023

California Independent System Operator governing entities in December adopted policies and tools to support system reliability.

The ISO’s Board and Western Energy Imbalance Market Governing Body approved the Energy Storage Enhancements and Resource Sufficiency Energy Enhancements initiatives in a joint meeting.

Both proposals are scheduled to be implemented by this summer when extreme heat can create high
demand for energy resources during critical hours.

With nearly 5,000 megawatts of storage resources now connected to the grid, the storage enhancements proposal reflects the ISO’s continuing work with industry stakeholders to refine its policies ensuring batteries are accurately priced in the real-time market and fully charged to provide energy when needed, CAISO said.

The Energy Storage Enhancements proposal adopted by the Board and WEIM Governing Body encompassed several refinements, including:

The Board and Governing Body also approved the WEIM Resource Sufficiency Evaluation Enhancement Phase 2 initiative to make sure the WEIM entities have enough capacity and energy in the real-time market to meet their demand before voluntarily transferring electricity to other participants.

APPA Details How it Can Help Implement DOE Cybersecurity Grant and Technical Assistance Program

December 20, 2022

by Paul Ciampoli
APPA News Director
December 20, 2022

There are a number of ways in which the American Public Power Association (APPA) can help the Department of Energy successfully implement a Rural and Municipal Utility Advanced Cybersecurity Grant and Technical Assistance Program including assisting in identifying solutions as well as potential pathways for increasing information sharing with small- and medium-sized public power utilities, APPA said.

APPA made its Dec. 19 comments in response to a request for information (RFI) issued by the U.S. Department of Energy’s (DOE) Office of Cybersecurity, Energy Security, and Emergency Response (CESER) to inform its implementation of the Rural and Municipal Utility Advanced Cybersecurity Grant and Technical Assistance Program.

In its comments, APPA noted that public power utilities are eligible entities for the new program, with over 1,000 of these utilities likely to fall into one or more of the priority categories of: (1) having limited cybersecurity resources; (2) owning assets critical to the reliability of the bulk power system; or (3) owning defense critical electric infrastructure (as defined in section 215A(a) of the Federal Power Act.

APPA said that along with awarding grants directly to owners and operators to address individual entity needs, DOE should also consider working with trade associations and other trusted partners around technical assistance options and needs.

“The needs of eligible utilities are diverse — some entities are in need of technical assistance on simply how to begin or move forward with basic programs, whereas others are more advanced and may be in need of assistance (financing and/or technical) in implementing technology or other cybersecurity solutions,“ APPA said.

APPA “presents a robust pathway for assisting large swaths of these communities, especially for those whose cybersecurity preparedness is not as mature as others,” it said.

For smaller utilities — including many public power utilities that make up the majority of eligible utility entities for this new grant program — cybersecurity can be daunting task, APPA pointed out.

“Many public power utilities have limited resources to put toward cyber services, technology deployments, additional cyber staff, or to increase participation in threat intelligence information sharing programs. Moreover, most public power utilities are distribution only utilities, whereas most existing government cybersecurity resources are focused on the bulk electric system (BES).”

The program’s focus on small- and medium-sized electric utilities, particularly public power and rural electric cooperative utilities, is a welcome development, the trade group told DOE.

In addition, APPA encouraged DOE to work with trade associations to reach their smaller members to ensure they are engaged and have clear pathways for resources available under the program.

APPA pointed out that it has worked with DOE through cooperative agreements on efforts like increasing increase adoption of cybersecurity solutions for operational technologies. This work has included the production of templates and guidance to assist in the adoption of these types of technologies, such as data sharing considerations.

APPA went on to note that tools and resources that are specifically intended for small distribution utilities are more likely to be utilized. “Therefore, it would be beneficial for DOE to consider pathways for creating, updating, or promoting these types of materials and resources.”

It would also be beneficial, when it comes to public power utilities, for DOE to consider ways it could partner with the Department of Homeland Security to identify tools and resources that DHS has already created for State, Local, Tribal, or Territorial communities that could be promoted, updated, and utilized by public power utilities, APPA told DOE.

“APPA is very interested in assisting and promoting such an effort within its membership, including bringing members to the table to help shape such products.”

These efforts would need to be complementary, not in place of, individual grant awards to qualifying utility owners and operators to implement solutions they have individually identified, the public power trade group said. “Access to a trusted community-focused forum where best practices can be confidentially shared and learned from would be very valuable for these communities.”

APPA also said the program will provide opportunities for smaller utilities to lean further in on cybersecurity issues to the benefit of their communities and the nation. “The ease of the process and the ability for smaller utilities to meet program requirements will be enormous factors in how much traction this new program is able to generate. To that end, DOE should also seek opportunities to limit the application of cost share or compliance reporting requirements, as these obligations may place an undue administrative burden on smaller utilities and be a significant barrier to participation.”

NERC Warns Changing Nature of Grid Could Threaten Long-Term Reliability

December 20, 2022

by Peter Maloney
APPA News
December 20, 2022

To ensure reliability, planners and operators of the electric power system will need to be particularly vigilant about the changing characteristics of the grid, according to the latest Long Term Reliability Assessment from the North American Electric Reliability Corp.

“The bulk power system is undergoing unprecedented change on a scale and at a speed that challenges the ability to foresee and design for its future state,” John Moura, NERC’s director of reliability assessment and performance analysis, said in a statement. “Managing the transformation and proactively preparing for the role that the grid will play is the greatest challenge to reliability over the next 10 years.”

Without careful planning, five trends could negatively impact the ability of the bulk power system to service the energy needs in North America over the next 10 years, the assessment said. Those trends are integration of inverter-based resources, growth in distributed energy resources, generation retirements, flat transmission growth, and increased demand growth.

While most areas in North America are projected to have adequate electricity supply resources to meet demand associated with normal weather, reserves in some areas do not meet resource adequacy criteria, NERC said.

Those areas are the Midcontinent Independent System Operator, California, and Ontario.

MISO is projected to have a 1,300-megawatt shortfall next summer that could continue to grow throughout the 10-year assessment period as coal, nuclear and natural gas generation retire faster than replacement resources are connecting, the assessment said.

California is adding enough new resources and retaining sufficient key generators to alleviate near-term capacity shortages, but variable resource output and changing demand could cause energy shortfalls, ranging from 1 to 10 hours, NERC projected.

Ontario will have a reserve margin shortfall of 1,700 MW beginning in 2025 that will continue to grow throughout the 10-year assessment period because of generation retirements and lengthy planned nuclear maintenance outages.

In addition, extreme weather events, like 2021’s Winter Storm Uri, and recent widespread heat waves in the West will continue to strain electricity resources over major parts of North America, even in areas where traditional resource adequacy criteria are met. In particular, the assessment noted that the U.S. Western Interconnection, Texas, New England and the Southwest Power Pool area are at “elevated risk of shortfall” during extreme weather events.

To ensure continued reliability, NERC recommended that grid planners and regulators should:

Last month, in its Winter Reliability assessment, NERC warned of insufficient electricity supplies this winter, identifying the Electric Reliability Council of Texas, MISO, SERC-East, Western Electricity Coordinating Council-Alberta, Northeast Power Coordinating Council (NPCC)-Maritimes, and NPCC-New England as the regions most at risk.

APPA “Beyond Disappointed” Transformer Production Funding not Included in Bill

December 20, 2022

by Paul Ciampoli
APPA News Director
December 20, 2022

The American Public Power Association “is beyond disappointed that funding to ramp up production of distribution transformers through the Defense Production Act” has not been included in the Dec. 19, omnibus appropriations bill, Joy Ditto, President and CEO of APPA, said on Dec. 20.

“This is a critical issue that several industries have raised, and on which the President has called for action. Despite our collective pleas over the past year to address this issue, supplies continue to dwindle, demand far outpaces production, and if action is not taken in the near term, the U.S. will face electric reliability concerns,” she said.

Electricity “is vital and underpins all aspects of our modern society. Without the reliability ensured by a steady supply of distribution transformers, we can’t accomplish any of our energy goals—including transitioning to cleaner energy sources or growing a strong economy,” Ditto said.

She said that APPA will continue to work “with our electric utility brethren and government partners to address this situation. We will also continue outreach to transformer manufacturers to seek their input on ways to step up to the challenge of adequately meeting the demand for these critical grid components.”

In recent comments submitted to the Department of Energy, APPA, the Edison Electric Institute, and the National Rural Electric Cooperative Association, said that DOE should use Defense Production Act authorities to prioritize distribution transformers, large power transformers, and other critical grid components ahead of other technologies, and it should act quickly to alleviate the most acute supply chain challenge with distribution transformers.

Groups Urge Congressional Appropriators to Fund DPA Authorities to Address Supply Chain Shortages

APPA and the electric trades augmented their comments on DPA with a letter for action on Capitol Hill. The electric trades, along with building trade organizations, recently sent a joint letter to Congressional Appropriations leadership requesting funding for DPA.   

The groups requested that Congress appropriate $1 billion this year for the implementation of DPA authorities to specifically address the supply chain crisis for electric distribution transformers.

FERC Proposes to Update Regulations on Transmission Backstop Siting Authority

December 19, 2022

by Paul Ciampoli
APPA News Director
December 19, 2022

The Federal Energy Regulatory Commission (FERC) recently issued a notice of proposed rulemaking that proposes to update its regulations implementing its backstop siting authority for electric transmission facilities under section 216 of the Federal Power Act (FPA), which was recently amended by the Infrastructure Investment and Jobs Act (IIJA).

The IIJA amended FPA section 216 to modify the circumstances under which the Secretary of Energy may designate national corridors and to clarify the circumstances giving rise to the Commission’s jurisdiction. 

The NOPR issued by FERC on Dec. 15 proposes revisions to the Commission’s regulations to ensure consistency with the IIJA’s section 216 amendments, to modernize certain regulatory requirements, and to incorporate other various updates and clarifications.

Along with making various revisions and updates to the Commission’s regulations, the NOPR proposes four overarching clarifications and additions.  

First, in accordance with the IIJA, the NOPR clarifies the Commission’s siting authority by expressly stating that FERC may issue a permit for the construction or modification of electric transmission facilities in DOE-designated national corridors if a State has denied an application to site transmission facilities.  

A 2009 ruling by the U.S. Court of Appeals for the Fourth Circuit had concluded that the version of section 216 enacted in 2005 did not allow FERC to invoke its backstop siting authority where a state regulator denied a permit application, as FERC had found.  The court ruling significantly limited FERC’s backstop siting authority, and the recent IIJA amendments effectively overrule the Fourth Circuit’s decision by clarifying that FERC can act even where a State has denied a permit application.

Second, the NOPR announces a proposed change in Commission policy that would eliminate the one-year delay following the submittal of a State application before the Commission’s mandatory pre-filing process may commence. Instead, the Commission proposes to allow the simultaneous processing of State applications and Commission pre-filing proceedings. This change will allow applicants to simultaneously pursue approval before a state and the Commission if they so choose, FERC staff noted in a presentation at the agency’s monthly meeting. 

Out of respect for state siting processes, the NOPR proposes to provide an additional opportunity for State input before the Commission determines that the pre-filing process is complete and that an application may be filed, FERC staff said.

Specifically, one year after the commencement of the Commission’s pre-filing process, if a state has not made a determination on an application, the NOPR proposes to establish a 90-day window for the state to provide comments on any aspect of the pre-filing process, including any information submitted by the applicant.

Third, the IIJA added a new clause requiring the Commission to determine that a permit holder “has made good faith efforts to engage with landowners and other stakeholders early in the applicable permitting process” as a precondition to the permit holder acquiring the necessary right-of-way by eminent domain. 

The NOPR proposes that one way for an applicant to demonstrate that it has met the “good faith efforts” standard is to elect to comply with an Applicant Code of Conduct in its communications with affected landowners. 

The Code of Conduct includes particular recordkeeping and information-sharing requirements for engagement with affected landowners, as well as more general prohibitions against certain misconduct in such engagement. 

Although a commitment to the Applicant Code of Conduct is voluntary, an applicant that chooses not to comply with the Code of Conduct must specify its alternative method of demonstrating that it meets the good faith efforts standard. 

Fourth, the NOPR proposes to add three resource reports to the backstop siting permit application, including an Environmental Justice Resource Report, a Tribal Resources Report, and an Air Quality and Environmental Noise Resource Report. 

The information provided in these three resource reports, as well as in the other resource reports required in an application, will enable the Commission to fully evaluate the effects of a proposed project in furtherance of the Commission’s statutory obligations under the FPA and the National Environmental Policy Act, FERC staff said.

Comments on the NOPR are due 90 days after publication in the Federal Register.

Groups Urge Congress to Take Action to Prevent Elimination of $14 Billion in Subsidy Payments

December 19, 2022

by Paul Ciampoli
APPA News Director
December 19, 2022

The American Public Power Association (APPA) and other trade groups are urging congressional leaders to waive the statutory Pay-as-You-Go-Act of 2010 (PAYGO) before the close of the 117th Congress.

“Failure to do so will result in the elimination of $14 billion in subsidy payments to public entities across the country,” the groups said in their Dec. 15 letter. “Subsidy payments from our federal partners are currently included in the budgets of thousands of jurisdictions. Without certainty of receipt, essential public services may become acutely impacted.”

APPA and the other groups are members of the Public Finance Network, representing nearly fifty thousand public organizations and issuers of municipal securities.

APPA is also urging its members to reach out to their congressional delegation to ask for relief from Statutory Pay-As-You-Go Act of 2010 sequestration.

“As we collectively worked to emerge from the Great Recession over a decade ago, state and local governments and public entities across the country utilized options made available to stimulate the economy and undertook several hundred billion dollars in critical, long-term infrastructure obligations through the issuance of direct subsidy bonds,” the groups said.

At the time, the understanding was that federal payments related to these bonds would not be subject to the appropriation process and would not be subject to sequestration, APPA and the others said.

“To our dismay, the federal government appears on the brink of completely reneging on this deal by eliminating $14 billion in payments to state and local entities. Specifically, unless new legislation is enacted that will waive the PAYGO as relates to the budgetary effects of the American Rescue Plan, thousands of state and local entities will not receive any Build America Bond (BAB), Qualified School Construction Bonds (QSCB), Qualified Zone Academy Bonds (QZAB), New Clean Renewable Energy Bonds (New CREB), or Qualified Energy Conservation Bonds (QECB) payments otherwise guaranteed to them under the law.”

Entities that issued these bonds generally in 2009, 2010, and 2011 did so in partnership with the federal government. For example, a BAB is a type of municipal bond designed to expand the pool of investors for municipal debt at a time when investment in traditional tax-exempt municipal bonds was in decline.

Additionally, projects financed with these bonds helped provide jobs and needed infrastructure investments when the economy needed it most. Unlike a traditional municipal bond, interest on a BAB is taxable to the bondholder and the interest rate paid is higher than for a traditional tax-exempt bond. However, Treasury is required to reduce this additional expense by providing a payment to the bond issuer equal to 35 percent of the interest paid to the bondholder, the groups noted.

In all, nearly 2,400 communities issued BABs to finance $180 billion in infrastructure projects, including school construction, water and sewer improvements, hospital and other health care system upgrades, highway and public transit investments, and electric power utility transmission, generation and distribution.

“Insofar as Congress fails to prevent these credit payments from being eliminated under PAYGO sequestration, it will be our residents who ultimately pay for the increased project costs.”

The groups also noted that Congress sought to make energy investment incentives available to not just investor-owned utilities and merchant generators through the creation of new CREBs to be issued by public power utilities and rural electric cooperatives. This change was made to ease the concentration of tax creditable energy project ownership by merchant power generators.

More than 800 public power utilities, school districts, city governments, and rural electric cooperatives were allocated more than $2.2 billion in new CREB bonding authority to finance, wind, solar, hydropower, and biomass projects. If Congress allows new CREB payments to be eliminated, it will result in their customers either seeing an increase on their monthly bill or in reduced resources available for investments in grid security and reliability, the groups warned.

“Payments to issuers of these special purpose bonds are already laboring under a steady stream of cuts triggered by the Budget Control Act of 2011 due to the failure of the Joint Select Committee on Deficit Reduction. These ‘Joint Committee Reductions’ began in 2013 and are now expected to continue through 2031. Joint Select Committee reductions will have cut payments by nearly $3 billion by the end of Fiscal Year 2022 and will cut payments by another $1.6 billion by the end of Fiscal Year 2031,” the letter said.

Allowing joint committee reductions to continue “is a travesty because so many public entities depend on this federal-state-local partnership. However, allowing PAYGO to eliminate these payments entirely would be catastrophic to communities that stepped up during the Great Recession to try to create jobs when job creation was desperately needed, to students in schools that are already underserved and to renters and homeowners that are already struggling to pay utilities, taxes, and other bills,” the groups said. 

“As a result, we hope Congress will overcome its differences and fix this problem for all Americans. Thank you for your time and consideration.”

The letter was sent to House Speaker Nancy Pelosi, D-Calif., Rep. Kevin McCarthy, R-Calif., House Minority Leader, Sen. Charles Schumer, D-N.Y., Senate Majority Leader, and Sen. Mitch McConnell, R-Kentucky, Senate Minority Leader.

Research Examines Participation of Wisconsin Residents in Energy Assistance Program

December 18, 2022

by Paul Ciampoli
APPA News Director
December 18, 2022

Research funded by the American Public Power Association’s (APPA) Demonstration of Energy & Efficiency Developments (DEED) program examines awareness and participation of Wisconsin residents in a home energy assistance program.

“What dollar amount makes it worthwhile for a household to apply for heating and electric bill payment assistance? According to a recent study, that amount is $612. In a remarkable coincidence, $612 is the exact average statewide benefit received by income-qualified Wisconsin households last winter,” Wisconsin-based WPPI Energy said in a recent news release related to the study. The average included $417 toward heating expenses and $195 for electricity.

The research was initiated when the locally owned electric utilities that make up WPPI Energy’s membership sought more insight on how to best support income-qualified customers, WPPI Energy noted.

“Our joint-action agency is owned and driven by the not-for-profit electric utilities we serve,” said WPPI Energy Senior Energy Services Manager and study co-author Anna Stieve in a statement. “These public power utilities have a strong focus on customers and their communities. So, it’s a natural fit to investigate how to best support some of the most vulnerable residents.”

To help fund the research, WPPI Energy applied for and received a grant through APPA’s Demonstration of Energy & Efficiency Developments (DEED) program.

DEED funds research, pilot projects, and education to improve the operations and services of public power utilities.

The survey was conducted by the Dieringer Research Group with active involvement from Stieve and other WPPI Energy staff experts.

The results revealed that seven out of 10 qualified households were aware of the Wisconsin Home Energy Assistance Program (WHEAP), with women and older residents demonstrating greater knowledge of the assistance available. Notably, only 27% of income-qualified residents applied for the WHEAP benefits available to them.

With respect to the question of why such a large population of eligible residents did not apply for assistance, many indicated they did not believe they would qualify, or did not feel they had a need. One-third of respondents didn’t want to ask for help, and another 16% felt other people needed it more than they did.

“Our survey uncovered that a lot of people don’t apply when they could really benefit from the program,” said Stieve. “This money is set aside to help pay heating and electric bills for those who qualify, and we really want to spread the word so customers don’t miss out on support that’s meant for them.”

To help better understand how to get this message out to customers, the survey asked how respondents heard about WHEAP in the past, and how they preferred to learn about energy assistance programs in the future. Customers would prefer to receive information through utility bill inserts, but are actually more likely to learn about the program through word of mouth.

Marketing Manager Steve Lightbourn, the study’s other co-author, says this and other insights from the survey will help WPPI Energy member utilities spread awareness and hopefully eliminate the stigma associated with receiving assistance.

“When customers take advantage of the programs available to them, it makes the entire community stronger,” continued Lightbourn. “Our member utilities want to support the people they serve, and promoting WHEAP is one of the easiest and most effective ways to do that.”

California Regulators Issue Major Decision on Net Metering

December 18, 2022

by Peter Maloney
APPA News
December 18, 2022

The California Public Utilities Commission (CPUC) on Thursday issued a decision revising the state’s Net Energy Metering (NEM) solar tariff to better reflect value of solar power and solar plus storage to the state’s grid.

The new NEM changes how customers of the state’s investor-owned utilities will be paid for solar power they do not consume and ship to the grid, basing those exports on the utilities’ avoided costs of buying clean electricity elsewhere rather than the utilities’ retail price of electricity.

The decision (Docket #: R.20-08-020) will promote solar exports during the late afternoon and early evening hours, particularly in the summer, when the grid is the most stressed, the CPUC said. The decision has no impact on existing rooftop solar customers, maintaining their current compensation rates.

The CPUC decision also provides extra electricity bill credits to residential customers who adopt solar or solar paired with battery storage in the next five years, which are paid on top of the avoided cost bill credits. Customers are guaranteed the extra bill credits for nine years.

The new NEM tariff also increases the allowable size of rooftop solar systems to cover 150 percent of a customer’s electricity usage in order to accommodate future electrification of appliances and vehicles. And the new NEM regime will also expand access to solar and storage for low-income customers, residents living in disadvantaged communities, and residents living in California tribal communities by providing a larger amount of extra bill credits.

The decision also applies new residential rates that have “significant differences” between peak and off-peak prices as a way of creating incentives for battery storage and load shifting from evening hours to overnight or midday hours, the CPUC said. The new rates aim to incentivize adoption of technologies to replace the use of fossil fuels such as battery storage, electric vehicles, and heat pump water heaters.

Reform of California’s net metering regime was mandated by a 2013 state law, Assembly Bill 327. The CPUC revised its original solar tariff program in 2016, creating NEM 2.0 and, most recently, revised its NEM proposal in November after the inclusion of a grid participation charge met with heavy criticism from many stakeholders.

FERC Directs NERC to Assess Effectiveness of Physical Security Reliability Standard

December 17, 2022

by Paul Ciampoli
APPA News Director
December 17, 2022

The Federal Energy Regulatory Commission (FERC) on Dec. 15 issued an order directing the North American Electric Reliability Corporation (NERC) to submit a report to the Commission analyzing the effectiveness of the existing NERC reliability standard addressing physical security of the bulk power system.

At its monthly open meeting, FERC directed NERC to conduct a study evaluating the need for improvements to Reliability Standard CIP-014-3, which pertains to physical security for the electric grid.

FERC staff noted that in recent months, there has been an increase in reports of physical attacks on electric substations that in some incidents have resulted in thousands of customer outages. In early December, Duke Energy responded to power outages caused by vandalism against utility equipment in North Carolina.

In its order, FERC requires NERC to provide an assessment of the effectiveness of the physical security reliability standard that considers, but is not limited to, the potential risks highlighted by recent events. 

Specifically, the order directed NERC to conduct a study evaluating:

The report is due 120 days from issuance of the order.