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Generators Say FERC Study Should Include Utility Data
Several generators recently expressed a willingness to cooperate with FERC as the Commission mulls how best to gather data related to generator outages in California, but they also questioned why FERC is not casting a wider net to include data from investor-owned utilities (IOUs) in the state.
FERC earlier this month issued a request for comments on an emergency proposal to collect information on generator outages in California. In the notice, the Commission proposes to collect information from selected generators in the state related to the cause and nature of individual outage events. Generators would have to report information related to total or partial generation unit outages within 24 hours of their occurrence. The reporting obligation would apply to all outages, whether scheduled or forced, occurring in an 180-day period.
In recent comments filed with the Commission, Reliant Energy Power Generation Inc. (REPG) and affiliates of Dynegy and Mirant all said that they do not oppose the idea of providing this type of data to FERC, but did express reservations about some aspects of the Commission’s proposal.
REPG, for example, pointed out in its filing that FERC has said that it is collecting outage information in response to high prices and blackouts in California so that it may monitor generation outages and assess their causes. To accomplish this objective, REPG said FERC should obtain comprehensive data regarding outage conditions in the California market. “Inexplicably, however, the Commission has excluded approximately one-third of the state’s generation by failing to extend the reporting requirement to the IOUs,” REPG went on to say. Just because IOUs self-schedule their generation to meet their load does not change the fact that loss of generation from the IOUs will have a “significant impact” on market conditions in California, REPG asserted. “By focusing exclusively on select generators, the Commission is creating the potential for misleading analysis and incomplete conclusions that will have limited utility,” REPG added.
Similar concerns were voiced in comments filed by Dynegy Power Marketing Inc. and several affiliates. Joining Dynegy Power Marketing in the filing were El Segundo Power LLC, Long Beach Generation LLC, Cabrillo Power I LLC and Cabrillo Power II LLC. Dynegy Power Marketing is the scheduling coordinator in California for these four generator affiliates and all four of the affiliates are owned equally by NRG Energy and Dynegy Power Corp. through their ownership interest in West Coast Power.
Dynegy Power Marketing and its affiliates said that they understood the Commission staff’s belief that it must monitor the California markets this summer. “What is not understandable and appears completely arbitrary is why Commission Staff would choose not to monitor generating facilities that are still owned by the IOUs — Pacific Gas and Electric Company, Southern California Edison Company and San Diego Gas and Electric Company,” Dynegy Power Marketing and its affiliates said. The commenters go on to note that these facilities make up approximately 50% of the generation in the California Independent System Operator’s markets. “There is no basis for excluding these units from the study,” Dynegy Power Marketing and its affiliates asserted.
For their part, Mirant Delta LLC and Mirant Potrero LLC sought clarification from FERC on a few issues related to the implementation of the proposal and the scope of reportable outages. Specifically, Mirant Delta and Mirant Potrero asked that the Commission provide clarification at the outset as to the kinds of events or operational conditions that must be reported, particularly as it relates to partial outages.
Mirant Delta and Mirant Potrero also asked for clarification from FERC that the need to report a derating relates to a physical inability to operate at full capacity, and not to an environmental restriction or other permit-based restriction on operations if the unit can still be called on to run in an emergency.
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