By Okay&L Gates companions Theodore Paradise, Kimberly Frank, and Ruta Skučas.
December 8, 2023
How the Most Contingency of two,200 MW Was Recast to a 1,200 MW Ceiling
As coverage makers and vitality builders look to develop and interconnect massive offshore wind tasks in probably the most economically environment friendly and least environmentally impactful approach, a difficulty has developed. A comparatively latest restrict, set in place by the grid operator in New England in a planning course of doc, states that no single system lack of vitality, or “contingency”, could be bigger than 1,200 megawatts (MW). This 2016 addition to ISO New England’s (ISO-NE) Planning Process No. 5-6 is more and more creating consternation amongst each coverage makers and builders and threatening to lift the fee and impacts of offshore wind. A part of the reason being {that a} de facto commonplace has developed in Europe that makes use of 2,000 MW 525 kilovolt (kV) excessive voltage direct present (HVDC) cable techniques to interconnect offshore wind, with tens of billions of {dollars} of those techniques already ordered and scheduled to be in service by the top of this decade. The two,000 MW measurement permits for single wind tasks to be bigger and profit from economies of scale unfold over extra energy manufacturing per mission and vital reductions within the variety of HVDC transmission techniques wanted to attach these tasks to the grid. To fulfill New England’s projected want of 30,000 MW of offshore wind energy, 10 extra HVDC cables and related converters at a number of a whole bunch of hundreds of thousands of US {dollars} every can be required if the 1,200 MW single supply restrict continues to use.
On the identical time, the advanced and opaque historical past of the 1,200 MW restrict has led to the impression that this has been a long-standing ceiling within the area and a way that it could be a major effort to raise the restrict. If the 1,200 MW ceiling is comparatively latest, what’s the long-standing single supply New England loss restrict agreed to by the predecessors of the New York Impartial System Operator (NYISO), ISO-NE, and PJM Interconnection (PJM) in 1991? 2,200 MW. As an alternative of a ceiling, the 1,200 MW is a ground that the three techniques will redispatch energy flows on their system to take care of.
The 1991 settlement, the “Process to Shield for the Lack of Section II Imports,” set 2,200 MW as the only supply loss ceiling and established a course of for assessing situations within the NYISO and PJM techniques by means of an examination of seven reactive situations. In PJM, this consists of energy flows throughout three specified traces, and in NYISO, there are 4 monitoring factors consisting of voltages at three substations and energy flows on the Central East Interface. Any restriction beneath the two,200 MW stage all the way down to 1,200 MW, and any level in between, is an at the least hourly calculation involving a control-to-control room verify. The 1,200 MW worth doesn’t seem within the 1991 settlement, however is noticed by the three grid operators because the decrease restrict beneath which system operators will redispatch technology to take care of. The 1991 settlement was filed with the Federal Vitality Regulatory Fee (FERC) in Docket No. ER07-231-000 on an “informational” foundation in November of 2006 as a result of it didn’t include “charges, phrases, or situations” beneath the Federal Energy Act (FPA). FERC rejected that informational characterization in its January 12, 2007 order, and accepted the submitting beneath Part 205 of the FPA. The 1991 settlement could be discovered on the FERC web site utilizing the quotation 111 FERC ¶ 61,017.
The introduction of the 1991 Process to Shield for the Lack of Section II Imports
In sensible phrases, which means, since 1991 till the current day, assets just like the Section II HVDC line from Canada to america that may function at as much as 2,000 MW, the Boston-based Mystic Producing Station items 8 and 9, which collectively are a 1,600 MW single supply loss because of a standard pure fuel gas supply challenge from an adjoining liquefied pure fuel gasification facility, and the area’s two remaining nuclear vegetation, Seabrook in New Hampshire and Millstone in Connecticut, can all function above 1,200 MW and as much as their limits so long as system technology dispatch and ensuing energy flows on the New York and PJM techniques enable. The 2016 planning course of restrict solely applies prospectively to new assets – HVDC traces interconnecting offshore wind included.
As extra focus was positioned on the 1,200 MW restrict by coverage makers and builders, in March of 2023, ISO-NE despatched a letter to the Joint ISO/RTO Planning Committee requesting a coordinated examine amongst ISO-NE, NYISO, and PJM to find out if the 1,200 MW restrict might be raised. ISO-NE described the 1,200 MW design restrict as a method to handle the problem as considered one of “day by day unpredictability” concerning the dimensions of the only contingency restrict beneath the 1991 settlement. In its letter, ISO-NE notes the dimensions of bigger assets might be “constrained by an in any other case optimum interconnection design,” and asks the Joint ISO/RTO Planning Committee to evaluate the supply restrict to see if it may be elevated. ISO-NE famous the higher restrict for a single system contingency to be 2,000 MW — as an alternative of the said 2,200 MW — and sought examine as much as that decrease 2,000 MW restrict. Whereas a 2,000 MW working ceiling would accommodate the rising offshore wind transmission commonplace set in Europe, it’s price noting that that is nonetheless 200 MW beneath the utmost stage grid operators recognized in 1991 and is contained within the ISO-NE tariff, the one higher restrict in a doc that has been reviewed and accepted by ISO-NE’s regulator, FERC.
One attention-grabbing component of the ISO-NE request is that ISO-NE itself that has set the 1,200 MW ceiling as a design restrict, not PJM or NYISO. The ISO-NE might equally take away its self-imposed restrict and as an alternative abide by the hourly check-in set out within the 1991 settlement for brand spanking new assets as much as the two,200 MW ceiling.
Whatever the end result of the train that ISO-NE has undertaken, coverage makers and builders might also attempt to work round ISO-NE’s 1,200 MW ceiling by making certain that the lack of bigger cables doesn’t lead to a simultaneous lack of greater than 1,200 MW throughout the ISO-NE footprint. Options from business have included networking services from inception in order that there are a number of paths for energy to circulate. The arrival of HVDC breakers and industrial deployment of that know-how in western European over the following 5 years could make the networked answer possible, however the New England states should specify or agree upfront to networking in transmission requests for proposals and ISO-NE might want to affirm that extra transmission paths would tackle the only supply loss challenge.
Till considered one of these or one other answer to handle the lowered single contingency restrict is adopted, offshore wind tasks and transmission circuits in New England will probably proceed to see limits of 1,200 MW.
* As printed within the November/December version of Marine Know-how Reporter.
In regards to the Authors
Theodore Paradise is a companion in Okay&L Gates’ Boston and New York workplaces the place he assists shoppers in navigating the altering panorama of the electrical business, advising shoppers concerning ISOs and RTOs, offshore wind, and transmission improvement.
Washington, D.C., companion Kimberly Frank co-leads the agency’s world Energy follow group and focuses her electrical regulatory follow on representing shoppers in issues earlier than FERC and state utility commissions.
Ruta Skučas is a federal vitality regulatory and wholesale electrical energy markets companion in Washington, D.C., and advises shoppers on electrical and pure fuel issues earlier than FERC, in addition to ISOs and RTOs.
