Curran, Jennifer. "Beyond Order 1000: Seams Operations and Congestion Management." Presentation to the Harvard Electricity Policy Group's 83rd Plenary Session. Cambridge, MA, June 2, 2016.
Excerpt from the Executive Summary
The Environmental Protection Agency’s proposed Clean Power Plan (CPP), published in June 2014, raises substantial operational challenges for regional transmission organizations (RTOs). In the CPP, EPA specifies emission reduction targets for 49 of the 50 states, based on EPA’s modeling that purportedly shows that each state can achieve the specified reduction targets through the use of four “building blocks.” States are to develop plans to meet the targets between 2020 and 2030, and are offered “flexibility” to use any combination of the four building blocks specified and/or other means (if approved by EPA) to achieve these targets. The State plans – required by June 30, 2016 (unless an extension is granted) - must specify how each state intends to meet the targets.
While there are many issues, questions and concerns with the ability of states and utilities to meet EPA’s emission reduction targets based on the use of EPA’s four building blocks (or through other means), building block 2, in particular, raises substantial issues for systems operators and RTO/ISO market operations because it involves changing the current methods of how electricity is dispatched throughout the nation’s bulk power systems.
Either FERC or the states have always overseen how security constrained economic dispatch is conducted to maintain reliability while cost-effectively serving customers. But, if EPA’s proposed rule becomes final, it, and not the system operators that federal and state regulators have entrusted, will make such critical decisions for our nation’s utility customers regardless of costs.
EXCERPT FROM THE EXECUTIVE SUMMARY:
This paper is part of an effort to evaluate matters affecting price formation in the energy and ancillary services markets operated by Regional Transmission Operators (RTOs) and Independent System Operators (ISOs) subject to the jurisdiction of the Federal Energy Regulatory Commission (FERC or Commission). It focuses on operator-initiated commitments in the RTOs and ISOs and the challenges in internalizing all relevant physical and operational constraints in the day-ahead and real-time market processes. This paper defines an operator-initiated commitment as a commitment that is not associated with a resource clearing the day-ahead or real-time market on the basis of economics and that is not a self-schedule. Deeming an action to be “operator-initiated” is not intended to confer any judgment that the action is not appropriate or necessary to maintain reliability.