Note: Apparently IMEA will not provide us a copy of the video for everyone to watch, so I am now publishing this citizen commentary on IMEA’s Resource Planning presentation. It represents a copy/paste and edited consolidation of two emails to the NEST Energy Committee, where the formatting characteristics of the original emails change when copy/pasting from Microsoft Outlook using the WordPress editor.
Instead of a “highlights” report, my two emails to the NEST Energy Committee were my commentary on the IMEA board meeting’s Resource Planning presentation by the IMEA President and CEO.
We had received a copy of the slides in advance of the board meeting with the ask that we watch IMEA’s board meeting presentation to give the slides “proper context” before we offered comments.
I had waited to post with the expectation that IMEA would provide full transparency with a recording, so that all who could not attend the board meeting including our city council would have the same “proper context” opportunity to also use to evaluate my commentary as well as any by NEST too.
Please be aware that IMEA is not legally required to provide recordings of board meetings. And now IMEA is telling me in writing that no such record exists, even though the board meeting webinar indicated that a recording had started for a meeting that was set to be recorded.
Energy,
At this time, I’ve decided not to provide a report of last Thursday’s [Oct 24] IMEA board meeting highlights. Instead, this is my personal commentary on that IMEA board meeting’s resource planning presentation. It represents my opinions, notes, and citizen knowledge of IMEA.
A copy of the resource planning slides extracted from the full set of board meeting slides is available here. I did not try to compare against the slides we previously received the week before the board meeting.
In my opinion, the presentation at the end of a long meeting was too fast and too full of one-sided stories that I’m not gonna repeat. Please, I encourage you to discuss with others who attended the webinar. And I also ask that you join me in making your own request to Naperville and IMEA to provide public access to IMEA’s video recording of the board meeting’s presentation.
My 5-part commentary [originally 4 with part 5 added in the second email]:
First and foremost: IMEA continues to offer us no apparent efforts or plans to consider alternatives that would support turning down the dial on that coal-fired ownership generation.
- Nothing is apparently planned until such time as required by State or Federal legislation or regulations.
- We also learned earlier in the board meeting that Prairie State continues to pursue funding of the carbon capture “experiment”. The Prairie State report slide listed: “Potentially explore the U.S. Department of Energy (DOE) Office of Clean Energy Demonstrations (OCED) for funding for carbon capture technology (NOI for funding issued by DOE)”
Second: IMEA continues to claim that IMEA makes resource decisions in open and transparent meetings. But I’ll assert that they are “forgetting” to tell the whole story when … .
When omitting mention of:
- The apparent lack of involvement and opportunities for input from our elected city council representatives, not to mention citizen stakeholders who are the “public” in public power.
- Apparently closed committee meetings in the development of the IMEA sustainability plan which was publicly revealed to us at the end of October 2023 IMEA board meeting after it was already developed
- Closed planning meetings such as the 2 days of closed IMEA board meetings in Nov 2019 for which the full meeting minutes continue to be voted by the IMEA board to be withheld from the public nearly 5 years later
Third: With the addition of the latest 150 MW solar project, there is no apparent room in the resource portfolio for further clean energy resources without …
- without turning down the dial on that coal-fired generation, or
- without an increase in IMEA power supply demand to be able to add to the resource portfolio.
My notes recorded a statement by the IMEA CEO that the IMEA portfolio now allows you Members to watch and wait as technologies develop before choosing new resources. Seems to me that also tells us in Naperville that we should also watch and wait before signing any IMEA contract extension.
Fourth: As I explain further, IMEA’s description of PJM accredited capacity requirements seems to also leave out the whole story.
And it may be highly misleading when using language such as: PJM requirements to have maximum peak load capabilities plus reserves. But I also acknowledge that I could be wrong in my understanding, and perhaps my research as an amateur citizen may be faulty. I’ve shared my research with our Naperville Electric Director, and it’s my understanding that he will discuss with IMEA. I’ll share with you what I hear further.
- It’s my assertion that it’s an IMEA business decision whether/how to hedge (offset) the PJM market prices for capacity. These are costs that IMEA must pay through the PJM Locational Reliability Charge. Instead, IMEA words seem to state that it is PJM requirement that IMEA have the accredited capacity to meet IMEA peak load plus reserves.
- My research plus evidence from IMEA’s Sept 2023 PJM settlement statement tells me that it’s IMEA’s responsibility as a Load Serving Entity (LSE) to pay for its share of the costs of the accredited capacity resources that are committed through the PJM capacity market processes. These processes are referred to as PJM’s Reliability Performance Model (RPM). And the costs are paid by all PJM LSEs, including IMEA, through the PJM Locational Reliability Charge which is calculated using summer peak
- An LSE may choose (but is not required) to offset all or part of the Locational Reliability Charge. One way is to offer owned resources in the capacity market and/or to use bilateral contracts to obtain RPM Auction credits. These credits offset the Locational Reliability Charge. In the Sept 2023 IMEA PJM settlements statement, there was such an RPM Auction credit of $447,853 that served to offset a substantial portion of the Locational Reliability Charge of $532,859
- For IMEA, it is a business decision whether, how, and how much to hedge (offset) the market price for capacity as reflected in the Locational Reliability Charge. And in times of volatile capacity market prices, there may be even further reasons to choose to do so. But it is not a PJM requirement that IMEA must acquire accredited capacity. And it is not a PJM requirement that would directly prevent IMEA from adding renewable energy resources to its portfolio.
At the end of the day, IMEA does not tell us the whole story of accredited capacity nor does IMEA provide continued transparency to the related PJM charges and credits that are hidden/buried inside IMEA Purchased Power totals in the IMEA financial statements.
Further sources and details on IMEA’s PJM accredited capacity requirements and PJM charges to IMEA for its LSE share of accredited capacity are listed at the end of this email.
Fifth: In the concluding part of his presentation, the IMEA President and CEO repeated the disinformation on IMEA keeping the lights on.
- It’s disinformation that we have debunked and that I believe we must continue to debunk because apparently it’s still useful and effective for IMEA to keep repeating.
- As he concluded his presentation, the IMEA President and CEO talked about IMEA managing the energy markets and the times when the wind doesn’t blow and the sun doesn’t shine.
- Then he described IMEA staff in the IMEA control room 24 x 7 every day of the year “optimizing which resource … the best cost … and keep the lights on for all 32 of our members … for the long term”.
- Please I urge all of you to keep refuting this IMEA disinformation. It’s PJM and Naperville Electric that keep the lights on in Naperville, not IMEA.
Further below are resources to refute IMEA keeping the lights on:
—
Ending this email with a repeat of my ask that you discuss with others who attended the webinar.
And please also request a copy of the recording. Didn’t we hear that this is supposed to be open and transparent IMEA?
Thanks.
Greg
Further sources and details on IMEA’s PJM accredited capacity requirements and PJM charges to IMEA for its LSE share of accredited capacity:
Open Access Transmission Tariff
Attachment DD
Reliability Pricing Model
5.1 Introduction
https://agreements.pjm.com/oatt/5141
In accordance with the Reliability Assurance Agreement, each Load Serving Entity is obligated to pay a Locational Reliability Charge for each Zone in which it serves load based on the Daily Unforced Capacity Obligation of its loads in such Zone. An LSE may offset the Locational Reliability charge for a Delivery Year, in whole or in part, by: (a) Self-Supply of Capacity Resources in the Base Residual Auction or an Incremental Auction; (b) offering and clearing Capacity Resources in the Base Residual Auction or an Incremental Auction (but only to the extent of the additional resources committed to meet Unforced Capacity Obligations through such Incremental Auction); (c) receiving payments from Capacity Transfer Rights; or (d) offering and clearing Qualifying Transmission Upgrades in the Base Residual Auction.
Reliability Assurance Agreement
Schedule 8
Determination of Unforced Capacity Obligations
https://agreements.pjm.com/raa/4176
A. For each billing month during a Delivery Year, the Daily Unforced Capacity Obligation of a Party that has not elected the FRR Alternative for such Delivery Year shall be determined on a daily basis for each Zone as follows:
Daily Unforced Capacity Obligation = OPL x Final Zonal RPM Scaling Factor x FPR
Where:
OPL = Obligation Peak Load, defined as the daily summation of the weather-adjusted coincident summer peak, last preceding the Delivery Year, of the end-users in such Zone (net of operating Behind The Meter Generation, but not to be less than zero) for which such Party was responsible on that billing day, as determined in accordance with the procedures set forth in the PJM Manuals, and as adjusted further to include the Obligation Peak Load associated with any Large Load Adjustment that may be allocated to the Party
Final Zonal RPM Scaling Factor = the factor determined as set forth in sections B and C of this Schedule
FPR = the Forecast Pool Requirement
PJM Manual 18: PJM Capacity Market
https://www.pjm.com/directory/manuals/m18/index.html#about.html
Two line items in IMEA’s Sept 2023 PJM settlements statement:
Charges for IMEA’s share of the costs of the accredited capacity resources that are committed through the PJM capacity market processes which may be offset by credits from the RPM Auction for self-supplied resources (owned and contracted resources)
Locational Reliability Charge of $532,859.70
From PJM Manual 18:
All LSEs pay a Locational Reliability Charge equal to their Daily Unforced Capacity Obligation in a zone times the applicable Final Zonal Capacity Price.
LocationalReliabilityCℎarge = DailyUCAPOblig * FinalZonalCapacityPrice
Each LSE that serves load in a PJM Zone or load outside PJM using PJM resources (Non-Zone Network Load) during the Delivery Year is responsible for paying a Locational Reliability Charge equal to their Daily Unforced Capacity Obligation in a Zone times the applicable Final Zonal Capacity Price for that Delivery Year.
My calculations to “unwind” / determine the average daily IMEA capacity obligation:
2023/2024 Final Zonal Capacity Price for ComEd: $34.18 MW-day
$532,859.70 divided by 30 days in Sept = $17,761.99 per day (avg for Sept)
$17,761.99 divided by $34.18 MW-day = 519.66 MW per day (avg daily unforced capacity obligation for Sept)
RPM Auction credit of $447,853.80
From PJM Manual 18:
RPMAuctionCredits = MWClearedLDA * RCPLDA
Each generation, demand, energy efficiency, or QTU resource provider that clears Capacity Performance sell offer segments in an RPM Auction will receive a Daily Auction Credit equal to the total MW amount that cleared in Capacity Performance sell offer segments times the applicable LDA resource clearing price in such RPM Auction for the entire Delivery Year.
My calculations to “unwind” / determine the accredited capacity that cleared in the auction
2023 – 2024 BRA Resource Clearing Price (RCP) for Rest of RTO: $34.13 / MW-day
$447,853.80 / 30 days = $14,928.46 per day (avg for Sept)
$14,928.46 / $34.13 per MW-day = 437.40 MW-day (sold in the RPM auction)
Resources to refute IMEA keeping the lights on:
IMEA General Counsel’s words at the Winnetka IMEA presentation:
https://www.youtube.com/watch?v=4NpC9Fzbz8o&t=1981
“..and when the RTOs were first created
they really were thought of as controlling the wires
and controlling discriminatory issues about the wires
but what they really turned into is protecting the reliability of the wires
making sure there’s power flowing through the wires
and the way that they decided to do that was
to start an energy market and a capacity market
to control how the generators that connect to the wires are dispatched
so that we have a constant continuous flow of electrons flowing across the grid
so the grid doesn’t fall down and the lights don’t go out
so the RTOs essentially these days do all that stuff …”
PJM’s 3 priorities webpage with priority #1: Keeping the Lights On
https://learn.pjm.com/three-priorities
Al Karvelis’ Aug 20 public comments at city council.
https://youtu.be/R1UzGX23gOQ
My 3-part public comments in 2023 at city council:
- Naperville Electric focused
https://youtu.be/fx7puSEjidU - PJM’s role
https://youtu.be/Rx7G7WJjyh4 - IMEA’s role
https://youtu.be/oh5uBG7h998