[ferro-alloys.com]Exelon is pushing back on a procedural change at ISO New England that it says unnecessarily puts Boston-area electric reliability at risk by jumping to eliminate the out-of-market retention of its Mystic Generating Station in Massachusetts before a competitive process to resolve identified reliability concerns is finalized.

At stake is not just the fate of the Mystic natural gas-fired plant, but whether ISO-NE will be held accountable to following its tariff even when that could delay attainment of the grid operator's favored solution, Exelon contended in a complaint (EL20-52) filed with the US Federal Energy Regulatory Commission.

The complaint, submitted by Exelon's Constellation Mystic Power subsidiary, asks the commission to bar ISO-NE from implementing changes to the way the grid operator conducts an annual transmission security review of capacity auction retirement bids and associated network modeling. The company contends the changes, approved by stakeholders without commission review, violate ISO-NE's tariff, specifically regarding Order 1000 provisions on competitive transmission procurements.

Planning procedure revision

Exelon's concerns stem from changes made to ISO-NE Planning Procedure 10, which supports the forward capacity market, providing guidance as to when transmission projects may be included in the network model for a relevant capacity commitment period.

Proposed transmission projects that could alleviate the need to retain generators for transmission security are generally only modeled as potential solutions when sufficient milestones have been met, including thorough vetting by ISO-NE and a commitment to build, to demonstrate an ability to meet the reliability need in a timely fashion.

Planning procedure revisions adopted June 4 allow ISO-NE "to assume that the transmission security problem that requires retention of Mystic [Units 8 and 9] will be solved in time based merely on the submittal of non-binding offers in response to a competitive transmission request for proposals, dubbed the Boston 2028 RFP," Exelon said.

It argued that "the change makes no sense" and puts reliability in the New England region in jeopardy as "it will lead to retirement of Mystic [Units 8 and 9] based on mere speculation that adequate alternative reliability measures will be in place timely. History shows that such speculation is unfounded because new construction projects are often delayed."

Exelon also charged ISO-NE with prematurely identifying the incumbent transmission owner as the winner of the RFP without the proper, tariff-required analysis of all the projects, in an effort to truncate the competitive procurement process. Such action was necessary for a "vetted, approved and committed project" to be in place in time for the transmission security analysis that will be completed in August, as part of the run up to the next capacity auction slated for February 2021, Exelon said.

Bypass FERC review

It noted two prior attempts by ISO-NE to prevent the retention of the Mystic units for reliability that were rejected by FERC, and contended that the planning procedure revision was an attempt to do the same thing without needing FERC's permission.

But Exelon argued that because the procedural change would significantly affect rates, contradict ISO-NE's tariff and past FERC orders, and "unjustly and unreasonably gamble on uncertain methods of preserving reliability," FERC had the authority to intervene to prohibit the change.

"We urge the commission not to be lulled into the view that the ends justify the means in this instance; rather, the commission must consider the precedent it will set," Exelon said. "It is only by adherence to a commission-filed rate that all market participants may be confident that the results in the end are just and reasonable."

Fast track

Exelon asked FERC to fast-track its complaint and issue an order by August 4. Swift action is needed as ISO-NE is performing its transmission security review from June 11 through August 18 using the revised planning procedure, the company said.

"Action by August 4 will allow a reasonable amount of time (two weeks) for ISO-NE to correct its transmission security analysis by the August 18 deadline," Exelon added.

The complaint asks FERC to exercise its "remedial authority to require ISO-NE to re-commence its transmission security analysis using an unmodified Planning Procedure No. 10, and to follow its tariff process for Order No. 1000 competitive procurements."

Exelon acknowledged that FERC could take such action at any time, but said that "given the complex interactions between the dates" in the process to run up to and conduct the 15th forward capacity auction for delivery year 2024-25, "and the parallel interactions between the transmission procurement process and the FCA process, expedited action is warranted."

FERC has set a June 30 deadline for comments in the proceeding.

(S&P Global Platts)

• [Editor:王可]