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;" MISOSPPCAL ISOERCOTPJM ProposalReliabilityEconomicBased on Prod Cost Simulation%Cost Resp for Infrastructure UpgradesInitialPaid by Connecting GenPaid by Load Through RatesUltimateStudy CycleAnnual
Multi-yearPlanning Horizon
Study HorizonPrimary Study Years Financed by TOs / Constr PartiesSourcing StrategyAmount of RenewablesBalance of RenewablesWindSolarOtherLocation RequirementsIn versus Out of State!Balance of Other Needed ResourcesNuclearNatural GasLocation of RenewablesLocation of Other Resources"Criteria for Ordering TransmissionAt-Risk GenerationOther Policy InitiativesDemand ResponseModeled at PeakOther HoursEnergy EfficiencyModeled Over What HoursWhat Regs Drive At-Risk !Economic Determination of At-RiskWhat Magnitude of Gen At-RiskIn ISO versus From Neighbors+Process for Proposing Transmission ProjectsAnnual for near-term assessmentLong-term assessment looks at 10-year horizon for 100 kV and above and 20-year horizon for 300 kV and above; near-term assessment window is defined each year in scope documentTBD in scope document#15-month cycle initiated every yearScenario Planning Load ForecastsSourcing Strategies High NukeHigh GasHigh Off-Shore WindHigh Mid-West WindAccelerated Economic RecoverySlow Economic RecoveryStorage TechnologyStability AnalysisOperational Performance IssuesShort Circuit AnalysisTransfer CapabilityReduced CongestionReduced LossesNew TPL StandardsAging InfrastructureWindow of OpportunityQualifications to ProposeDetail of Proposals"Designation of Constructing EntityBasecase ViolationsScenarios with Least RegretsCriteria for Least RegretsDeadband for decision makingMerchant TransmissionMarket Revenue StreamsState CompactsCosts to Sponsoring StatesSafe Harbour ProvisionsCarbon regsOther environmental regsAbility to site projectsReduced RPS complianceAbility to financeCompetence to construct project PJM TodayAnnual for all assessmentsT5-year case, re-tool cases for earlier years, extrapolation analysis for later yearst15-years, 5-years primarily for lower voltages, 15-years primarily for higher voltages and longer lead-time projectsLinkage to proposing entitiesCirculation Flows(Model Some % Target Based on State Goals<Model Resources Required Based on State Goals in Legislation4Model Resources Required Based on State Energy PlansBasis For Source Location/Remove Specific Units or Derate Clases of UnitsAll NERC StandardsSubset of NERC StandardsOther Local StandardsBased on Prod Cost Savings$Based on Energy Cost Savings to LoadEnergy Delivery Measurement(Based on Aggregate MWhr Compared to Goal7Based on Individual Resource/Clusters by State or Other@[Note: Do operational issues impact scope of planning analyses?]Changes to Light-Load CriteriaOther Benefits MeasuredVoltage Stability AnalysisGenerator/Plant IssuesNetwork Reactive Issues)Criteria for re-evaluating past decisionsTreatment of Scenario Planning#Competence to own/maintain facilityBaseline & Scenarios-230kV &above violationsScenario Selection8-Baseline includes public policy mandates (conservative):-Group scenario drivers (left col.) based on common effect-5 scenarios & 1 baselineDemand Response (High&High Penetration (Includes Objectives)!Low Penetration (75% of Mandates)[ex) Low load Forecast Scenario (10% Lower) = Slow Economic Recovery and High DR PenetrationSolution Requirements*Cost of Solution:*Robustness (longevity & increaese in transfer capability)'*Least regrets- # of scenarios resolved8-Must best resolve violations in scenarios. Criteria are-*Economic benefits- total congestion relieved*Other?#-Must resolve baseline (brightline)Solution Selection Process:-Build upon and use PJM already proposed two-year process:;*PJM presents violations and issues for basline & scenarios*Same builder selection process#*Same Window for proposed solutionsOption A: PJM should exercise independent planner discretion for ordering transmission to resolve scenarios. Baseline is brightline. dOption B: Scenarios are planned for based on brightline criteria objectives. Baseline is brighline.Direct Energy Ideas Alternate Proposal CAlternate Proposal DAlternate Proposal E#Criteria Applied in Policy AnalysesHandiling of Nuclear UnitsHandiling of Mothballed Units4Ability to Schedule Transmission Maintenance Outages-Mitigation of Unacceptable Operational EventsEDoes Treament of Policy Initiatives Anticipate Revised TPL Standards?=Any Consideration of Aging Infrastructure in Policy Analysis?-3Testing/Sensitivity ScenariosHistorical Stress CasesReactive Load ForecastsReactive Resource Capabilities#(see new TPL for additional items) %Expiration / Resubmittal of Proposals,Criteria for Selecting Transmission Projects)Selection of Best Solution from ProposalsSelection MetricsHow Far Out Does It Resolve?Elimitation of Other Upgrades&How Long Before Needing Next Solution?Siting FeasibilityNModeling assumptions made about neighboring systems when evaluating own system%Issues Posed by Intermitent ResourcesDesignation by RTODesignation by StatesDesignation Metrics,Cost Estimates (pay me now vs. pay me later)Construction StandardsAbility to Operate and Maintain^The study cycle to address bottom-up reliability and economic projects is repeated every year.The study cycle to recommend top-down projects to address public policy requirements as well as regional economic and reliability issues are performed on a two to three year cycleU3-year cycle for long-term assessments (18 months for 10 year, 18 months for 20 year)3Long-term assessments to identify public policy, reliabliy and economic needs and evaluate alternative solutions that meet those needs are performed on a 15 to 20 year planning horizon. Short-term assessments to recommend specific projects for construction are performed on a 5 to 10 year planning horizon.OIn short-term assessments, renewable generation is strictly tied to actual laws and regulations. At the current time, these laws and regulations are state laws and regulations. For long-term assessments, multiple futures will be considered, including futures with laws and regulations that do not yet exist (e.g., federal rps, etc.).YesSPP does not determine how the members meet their state goals. When providing their forecasts they would include such evaluations. SPP does include a federal mandated RES policyBalance of renewables is driven by actual laws and regulations, but wind is generally assumed when laws and regulation do not dictate other types.Laws and regulations are strictly followed when they specificy requirements for in-state vs. out-of-state. In general, 50% of a specific state's requirements is targeted to be within the state based on input and guidance from stakeholoders and state regulators.Out of State ConsideredAll requirements are modeled within the Midwest ISO footprint based on the significant availability of wind areas within the footprint.Sourced from SPPGIn long-term assessments, nuclear and natrual gas may be simulated in specific futures when appropriate. In short-term assessments, no new generation is modeled other than what is needed to meet resource adequacy requirements or public policy requirements, unless such new generation has an executed interconnection agreement.Renewables are located within specific zones developed in collaboration with stakeholders and state regualtors. These wind zones are disbursed throughout the footprint and were established based on NREL wind data./Demand response programs, as known, are modeledModeled within the load forecast provided by Transmission Owners or if a market participant makes a commitment to pursue. Futures may have some variations in demand response as data supporting p< rojections is available.CWholesale Demand Response resources are modeled as a generators. AModeled within the load forecasts provided by Transmission OwnersEE products are not modeled at a wholesale level, but may be included in the numbers provided by members for the models based on their individual retail loads and forecasts.Unit retirements typically modeled in short-term assessments only when retirement is announced. Long-term assessments may model retirements as part of specific futures.KSPP is considering coal unit retirements for an ITP10 scenario under 200 MWNERC and Regional Standards.xEconomic benefits for MVP projects typically include production cost savings, capacity savings due to loss reductions during the system peak and capacity savings due to reduced planning reserve magins.For Market Efficiency Projects (MEPs), economic benefits are set by weighting production cost savings at 70% and cost to load savings at 30%. Stakeholders are currently reviewing this criterion and future modifications could be made to move away from LMP based benefits.dEnergy delivery is based on a combination of production cost simulations and power flow simulations.BYes if this means localized advancement towards an aggregate goal.JYes. Detailed transient and small signal stability analysis is conducted.Short-circuit analysis is conducted to determine if transmission project result in over-dutied circuit breakers. If so, circuit breaker upgrades can be added to the scope of the project.(Voltage stability analysis is conducted.}Operational issues can be considered in the planning analyses and may be used as a tie breaker between competing alternativesNoNot at this time.During long-term assessments such as the Regional Generation Outlet Study, the Midwest in collaboration with stakeholders used both a bottom-up and top-down process to proposed potential transmission projects. Stakeholders to review a more formal process in 2011 to go fwd. Current thinking is a window of time to accumulate proposals from stakeholders and from within, that have merit as candidates within a geographically diverse portfolio._For Multi Value Projects, the costs are allocated to Midwest ISO load on a postage stamp basis.REvery year for lower voltages, based on facilities with a primarily local functionS2-year cycle for higher voltages, based on facilities with a more regional function8-year case during first 12 months of 24-month cycle for higher voltages (regional projects), cases for further out years for market efficiency simulations, 5-year case each year for lower voltages, re-tool cases for earlier years, extrapolation analysis for later yearsNModel 100% of programs that are legislatively backed or enacted through policyFModel remaining needed resources as wind after solar and other (below)Model specific goals for solar/Model other sources where allowed - amounts TBDyMonitor satisfaction of in-state requirements through production cost simulations - adjust sourcing through sensitivities=Model 100% within PJM with sensitivities for external sourcestTarget 20% installed capacity reserves - add only renewables needed for goals - make up difference with gas and nukeZAdd two nukes in current 15-year case - Assumptions will be reviewed on an on-goings basisjAll reserve shortfall in shorter term cases and remainder after nukes in 15-year case will be natural gas Base case generally based on queue - solar in states based on goals - wind scenarios to vary from queue-based to higher ocean-based integrationWNukes based on most advanced queue positions - gas distributed on system based on queueBase case includes 100% of DR goals (in legislation of enacted through policy) - sensitivities will examine impact of lesser development or withdrawal of resources in future years - greater penetration will be examined based on development of market products<Traditional DR modeled as peak reducer per operational rulesONew products (PRD) modeled as TBD - need to work on how to model these productsTBD - Base case could model 100% of goals with sensitivity for lesser amounts or base case could track current performance with goals and sensitivities for higher amounts-TBD based on analysis of efficiency resourcesRun production cost simulations to test delivered MWHr - develop transmission upgrades and then test for complaince with all reliability standards and evaluate market efficiency benefits\Trigger violations at 100% of limit - don't back away from violation until reduced below 95%Exelon ProposalnPlanning criteria for public policy driven projects should encompass requirements of only laws, rules and regulations actually in effect in determining the impact on generation capacity, demand response, energy efficiency, etc. Conversely, PJM should not plan for additional public policy objectives not specifically required by state or federal laws or regulationsFGGState and federal laws, rules and regulations for which transmission expansion is planned must be observed in full, taking into account, for example, the Illinois rate increase cap on the RPS requirement, the cost of alternative compliance payments included in some RPS laws, and, if applicable, state preferences for resourcesstXWhat is the basis of using a target of 20% installed capacity reserves when IRM is less?SNeed to model requirements as opposed to goals that are not required or enforceableTNeed to model requirements as opposed to goals that are not required or enforceable.When issued as final EPA Rules: Utility MACT, 316(b), Transport Rules, Coal Combustion Residuals. All existing regulations modeledXNeed more information of which and a justification for modeling less than full standards,RFC/SERC Standards, Local standards as filedsMust be modeled, first to maintain reliaiblity at all load levels; and also as operational performance requirementsLAgree this should be a criteria; need some basis for unacceptable mitigationCompared to what? If project is justified under other criteria, then reduced losses need to be compared to reduction in losses of other options - benefit is not absoluteReduction in reserve levels if this can be quantified; if reduction is to a LDA(s) rather than entire RTO, this must be articulatedNeed specifics of what is planned for and criteria for inclusion in the RTEP as well as which projects should be supplemental projects/All regulations (whether or not being appealed)Must use assumptions that neighboring systems use for their planning (i.e., MISO assumptions used for MISO MTEP). This may mean a claim that MISO must pay for certain upgrades in PJM. Exelon prefers close coordination by neighbors and expansion of JOAs to do this. However, in the end, PJM cannot ignore or change the assumptions used by other planning entities whether or not PJM disagrees with those assumptions\Need to plan transmission for use of these facilities without burdening other prior installed resources. As an example, while wind generation may be assumed have available 13% at nameplate at peak, the system must be planned so that wind can operate at its full output without burdening other resources (or operating rules changed to that effect).Proposals must contain a technical analysis sufficient to show that the proposal would meet the region s planning requirements. Just proposing a facility without any analysis or without analysis that shows a colorable need is not a proposal. A simple variation of an existing proposal is not a new proposal. For example, eliminating or adding a substation to a proposed line is not a new proposal. Changing a double circuit to a <single circuit or vice versa is not a new proposal. Changing one end of a line to another substation wihout specific additional benefits is not a new proposal. Submitting a line and stating all variations therefore does not provide broader rights than above.YNo obligation of an incumbent TO to operate or maintain facilities built by another. Competence to own and maintain must include NERC compliance. This cannot be shown by stating that the entity will contract for the service. PJM needs to know that the entity performing these services is qualified and will be there to perform these services.Those who own property have no obligation to allow other entities to site facilities on their property. Any evaluation of the ability to site must include an evaluation of how long it will take to obtain property and the cost.#Needs to be an independent estimate
See above 8Must use at least equal to prevailing standard in a zoneNeed explanation/This is important - time to site also importantyFlows caused by other systems cannot be ignored; i.e., MISO flows from West MISO to East MISO must be modeled in basecaseThis is an important metric in meeting state/federal RPS laws, rules and regulations. Simply connecting generating without some reasonable assurance of ability to satisfy laws, rules and regulations will not be planning the PJM system consistent with those laws, rules and regulations.6However, model external RPS sources for impacts to PJMKFollowing cost benefit weighting threshold methodology developed within PJMANeeds definition of criteria for unacceptable operational events.gUntil new TPL standards are adopted at least by NERC Board, PJM should plan for existing TPL standards.Agree some criteria is needed to avoid seesawing. What is basis for 95% (at this point is arbitrary)? Need some justification for this level. Or at least an understanding as to whether 95% would resolve the seesawing experienced.1New entrant must meet exactly the same conditions that are imposed on Incumbent TOs. State requirements that apply to Incumbent TOs must also apply to new entrants. Examples include:" Books open for inspection
" Approval for financing
" State public utility certificate
" Economic wherewithal to operate and maintain all facilities reliably, with accountability at the holding company level, not at the project LLC level.
" Technical expertise and commitment to operate and maintain the proposed project reliably, 24/7, emergency restoration response (spare equipment inventory, on-call personnel, contractor relationships, specialized machinery) and in accordance with all regulatory standards/requirements. Prudency and reasonableness reviews identical to those incumbent TOs undergo.
"Not relying on unproven technologyvPJM cannot designate an entity that cannot by law build in a state or has no condemnation rights that may be required. Any proposal for designation by the states needs many more details. What would be the procedure? Would such a process be consistent with each states' laws or would different processes apply to each states? How would duplication of costs be minimized? How would the entities not chosen in the process to construct recover their costs? Note that at present, many transmission owners obtain land before filing for a certificate to keep the cost of land for the project down. How would a process deal with these issues?Exelon believes that the planning criteria and processes must be established first and only then can there be a discussion of cost responsibility (allocation).IRules must be established for the assignment of the 'right to construct.' If PJM makes a decision on specific criteria, does the entity now have a saleable right, and if so, under what conditions and what approvals are required. For example, what if the proposed assignee would not have been chosen based on its qualifications?Emprical results from the RPM auction process (not clearing once) in conjuction with the IMM's identification of units at risk based on a review of market revenues and costs (including costs of compliance) should be used as an early indication of units are risk. See above. Units that do not clear two base residual auction should be removed from service for purposes of performing baseline relaibility analysis.No special treatmentUnits mothballed and not offered into two RPM auctions should be removed from service for purposes of performing baseline reliability analysis.The process for Selecting Transmission Projects needs to include a comprehensive review of the long term plan for the area where multiple reliability, economic, and load serving issues could be addressed with the best overall plan identified. The plan also needs to consider siting issues including timing and feasibility concerns as well as recognition of right-of-ways that have already been securred. Alternate Proposal B7s
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