The Federal Energy Regulatory Commission (FERC) on June 16 launched two rulemakings aimed at improving the reliability of the bulk power system against the threats of extreme weather.
FERC noted that these are the first proposed rulemakings stemming from a climate change and extreme weather proceeding that the Commission initiated in June 2021.
Commissioners voted on the Notice of Proposed Rulemakings (NOPRs) at FERC’s monthly meeting.
NOPR on Transmission System Planning Performance Requirements For Extreme Weather
In one of the NOPRs (Docket No. RM22-10), FERC proposes to direct the North American Electric Reliability Corporation (NERC) to develop and submit for Commission approval modifications to Reliability Standard TPL-001-5.1 (Transmission System Planning Performance Requirements). The modifications will address transmission system planning for extreme heat or cold weather events that impact the reliable operation of the bulk power system.
FERC staff noted that this proposed rule focuses on Reliability Standard TPL-001 because this standard establishes transmission system planning performance requirements to ensure the reliable operation of the bulk power system over a broad spectrum of system conditions and following a wide range of probable contingencies, including extreme events based on operating experience.
However, while TPL-001 references studies for “extreme events,” it does not specifically require performance analysis for extreme heat and cold weather conditions that affect wide geographical areas simultaneously over several days.
In addition, FERC staff noted that while the standard requires responsible entities (i.e., planning coordinator and transmission planner) to evaluate possible actions to reduce the likelihood or mitigate the consequences of extreme events, these entities are not obligated to develop and implement corrective actions.
To address this reliability gap in bulk power system planning, the NOPR proposes to direct NERC to develop modifications to Reliability Standard TPL-001-5.1 to require responsible entities to:
- Develop benchmark planning cases based on information such as major prior extreme heat and cold weather events or future meteorological projections;
- Plan for extreme heat and cold events using steady state and transient stability analyses expanded to cover a range of extreme weather scenarios including the expected resource mix’s availability during extreme heat and cold weather conditions, and include the broad area impacts of extreme heat and cold weather; and
- Develop a corrective action plan that includes mitigation for any instances where performance requirements for extreme heat and cold events are not met.
In addition to extreme heat and cold weather events, the NOPR also seeks comment on whether drought should be included in the scope of Reliability Standard TPL-001 to be modeled in the future to improve system performance during these events.
One-Time Reports On Extreme Weather Vulnerability Assessments
In the second NOPR (Docket Nos. RM22-16 and AD21-13), FERC proposes to direct transmission providers to submit one-time informational reports describing their current or planned policies and processes for conducting extreme weather vulnerability assessments and mitigating identified extreme weather risks.
FERC staff noted that the NOPR builds on the record of FERC’s June 2021 Technical Conference on Climate Change, Extreme Weather, and Electric System Reliability. FERC staff said that during this conference there was widespread agreement that utilities and other industry participants should assess the vulnerabilities of their systems to these risks.
However, the record to date does not indicate whether and to what extent transmission providers are conducting extreme weather vulnerability assessments, the methods used to conduct those assessments, and what is done with the information from those assessments, FERC staff said.
The proposed one-time reports would ensure the Commission can fulfill its statutory obligations with respect to system reliability and just and reasonable rates.
FERC staff said the goal of this proceeding is to gather information, not to establish new requirements. Therefore, the NOPR does not require transmission providers to conduct extreme weather vulnerability assessments where they do not do so already, or to require transmission providers to change how they conduct or plan to do such assessments.
The NOPR proposes to define an extreme weather vulnerability assessment as any analysis that identifies where and under what conditions jurisdictional transmission assets and operations are at risk from the impacts of extreme weather events, how those risks will manifest themselves, and what the consequences will be for transmission system operations.
The NOPR also proposes to require transmission providers to submit one-time informational reports on how they: (1) establish a scope for their extreme weather vulnerability assessments, (2) develop inputs, (3) identify vulnerabilities and determine exposure to extreme weather hazards, (4) estimate the costs of impacts, and (5) develop mitigation measures to address extreme weather risks.
Commissioners Weigh In
“Increasingly frequent cold snaps, heat waves, drought and major storms continue to challenge the ability of our nation’s electric infrastructure to deliver reliable affordable energy to consumers,” FERC Chairman Richard Glick said in discussing the NOPRs. The actions “are necessary to ensure that we are prepared for the challenges ahead.”
Commissioner Willie Phillips in his opening statement for the meeting said he agreed with the NOPR on transmission system planning performance requirements for extreme weather “to emphasize the critical importance of ensuring that the bulk power system is prepared for extreme weather events in both the near-term and long-term.”
While the NOPR “has the potential to reduce the threat to the reliability of the electric system, I note that we must remain vigilant as much work remains to ensure reliable delivery of power to consumers during times of stress and to resolve resilience concerns on the transmission system,” he said.
“In my view, this NOPR is another step on the path to mitigating the long-term effects of extreme weather; however, I remain concerned about the grid’s near-term reliability, particularly during the upcoming summer and winter seasons,” he said.
Phillips also said that the regional nature of extreme weather “highlights the difficulties facing our industry in addressing highly variable risks. The challenges facing California are very different from the challenges facing Texas. I believe a minimum transfer capability requirement is needed, because enhanced transfer capability may be the best way to take advantage of the diversity of energy sources and the many ways in which we can support the grid.”
Commissioner Allison Clements offered a concurrence on the NOPR directing NERC to revise its transmission planning reliability standard.
She said that while the NOPR represents “an important step in tackling extreme weather’s myriad impacts on the transmission system, strong follow through from NERC will be required to ensure a reliability standard that addresses extreme weather reliability challenges in a comprehensive and cost-effective manner.”
Clements said that while the NOPR seeks comments on whether drought should be included along with extreme heat and cold weather events within the scope of Reliability Standard TPL-001-5.1, she believes “that what we already know about meteorological projections and drought’s anticipated impacts on the electricity system compel the development of drought benchmark events in applicable regions of the country.”
The question for her is not whether such events should be included, but how TPL-001-5.1 should cover the impact of drought induced reductions in supply on regions already experiencing unprecedented reductions in reservoir supply and increased wildfire risk.
Clements also said that it is important to note “that if we are to cost-effectively ensure system reliability as the frequency and intensity of extreme weather events continues to increase, further action is necessary to complement” the NOPR.
Commissioner James Danly, while concurring in both NOPRs, challenged the Commission’s focus on extreme weather. In his concurrence to the NOPR directing NERC to revise Reliability Standard TPL-001-5.1, he argued that “even if one were to grant that certain parts of the United States were experiencing statistically unusual weather when compared to historical baselines, that has absolutely nothing to do with whether the markets and regulated utilities are procuring sufficient generation of the correct type to ensure resource adequacy and system reliability.” According to Danly, weather is not the problem, “[t]he problem is federal and state policies which, by mandate or subsidy, spur the development of weather dependent generation resources at the expense of the dispatchable resources needed for system stability and resource adequacy.”
Comments on both proposals are due 60 days after the date of publication in the Federal Register.