The State-Led Market Study Roadmap; Market and Regulatory Review Report
July 30, 2021 (Energy Strategies)
Introduction and Background
The Utah Governor’s Office of Energy Development (OED) received a grant, in partnership with the State Energy Offices of Idaho, Colorado, and Montana, from the U.S. Department of Energy to facilitate a state-led assessment of organized electricity market options. The project is referred to as Exploring Western Organized Market Configurations: A Western States’ Study of Coordinated Market Options to Advance State Energy Policies1 or the “State-Led Market Study.” The objective of the “State-Led Market Study” was to facilitate a neutral forum, and neutral analysis, for Western States to independently and jointly evaluate options and impacts associated with new or more centralized wholesale electricity markets and their footprints.
The project is composed of two primary pieces of work:
• Technical Modeling (which is summarized in the companion “Technical Report”); and
• Market and Regulatory Review
This document comprises the Market and Regulatory Review and includes the Market Factor Scorecards, which evaluate how different potential wholesale market structures might facilitate achievement of each state’s energy policy objectives. The Market Factor Scorecards are based on two primary overarching state energy policy priorities, which were identified based on a review of participating state’s key energy policies conducted in 2019. For each of the two overarching state energy policy objectives, several metrics/factors are assessed for each market construct, resulting in the “scorecards” included in this report. The report also includes a scorecard for how each market construct might impact the retention of state regulatory authority. While retaining state regulatory authority is not an explicit state policy preference, it has the potential to impact a state’s ability to implement its other energy policy priorities and, thus, has been included in this report as a scorecard for ease of review by states and policy makers. Additionally, this report includes an appendix (Appendix 1) that provides findings based on research and analysis on likely approvals required for each market construct, as requested by the Lead Team. 2 This report and appendices comprise the final work products for the “Market and Regulatory Review” stream of work for this project.
2. Overview of Market Constructs and Assumptions
To perform the Market and Regulatory Review, it is first necessary to provide some definitions around each of the market constructs that will be evaluated. The more technical aspects and key modeling assumptions for each market are reviewed in the Technical Report which accompanies this document. But the key assumptions regarding these market constructs, which are likely to impact how each market construct does, or does not, contribute to achievement of the metrics for each overarching state policy objective, are reviewed here for the four different electricity market constructs that are assessed herein.
These market constructs are generalized and are intended to, at a high-level, capture qualities and benefits of different market options. Thus, it is important to understand that these generic market constructs will not, and are not intended to, capture the finer details of individual markets operated by different service providers. Consistent with the direction provided by the Lead Team in the Modeling and Analysis Request (“Request”), the Market and Regulatory Review does not specifically evaluate details of each market services proposal nor of potential market providers. Consequently, there may be differences in the underlying assumptions regarding a market construct and what is ultimately proposed or implemented by a particular market services provider.3
To support the Market and Regulatory Review, certain assumptions needed to be made about the underlying components of each of the market constructs. Table 1, below, outlines key assumptions regarding market constructs that are important for this assessment. A brief written overview of the market construct precedes the more detailed table of key assumptions regarding these markets.
A bilateral market is a market construct with no centralized, organized optimization of energy transactions. Trades of electricity occur “bilaterally” between two counterparties. This market construct generally has individual transmission tariffs and does not include Security Constrained Economic Dispatch (SCED).4 This type of market construct is often characterized by fragmented operational responsibilities and multiple Balancing Authorities (BAs). The “bilateral only” market construct, still exists in some areas of the West (namely, those that are not yet participating in a real-time electricity market).
A real-time market is an electricity market that settles—determines the price—for time periods of one hour or less during the day of delivery.5 In a real-time market, day-ahead unit commitment is not optimized across participants and non-real-time transactions continue to occur bilaterally. Examples of real-time markets include the Western Energy Imbalance Market (EIM) operated by the California Independent System Operator (CAISO) and the Western Energy Imbalance Service (WEIS) operated by the Southwest Power Pool (SPP)
The concept of a day-ahead market outside of the construct of a formal Independent System Operator (ISO) or Regional Transmission Organization (RTO) 6 has been contemplated, but to date, has not been implemented in the U.S. Generally, it is expected that a day-ahead market would entail centrally optimized day-ahead unit commitment and real-time dispatch, but participants would continue to administer their own transmission tariffs and transmission planning functions and would retain operational/functional control over their transmission systems. A similar concept was proposed by the (now) Midcontinent Independent System Operator (MISO) in 20087 and is currently being contemplated by both the CAISO and the SPP. 8
Regional Transmission Organization
An RTO or ISO is typically a non-profit organization that is tasked with ensuring reliability and optimizing electrical supply and demand bids for wholesale power in its footprint. ISO and RTO formation was primarily proposed, developed, and enhanced through various orders of the Federal Energy Regulatory Commission (FERC).9 RTOs and ISOs do not own generation or transmission, but they do perform a variety of tasks including managing transmission and energy flows across the market footprint, performing transmission planning within the market footprint, ensuring reliable operation of the grid, and managing wholesale energy market transactions and cash flows within the market. Examples of ISOs/RTOs include CAISO, SPP, MISO, and PJM Interconnection…
This report has reviewed the three Market Factor Scorecards developed as part of the State-Led Market Study. These scorecards evaluated how different potential wholesale market structures might facilitate the achievement of each state’s energy policy objectives. The scorecards and their associated metrics were developed based on two primary overarching Western state energy policy priorities and on how different market constructs might enable states to retain jurisdiction over key elements that may impact achievement of state energy policy priorities. The three scorecards assessed in this report were:
1. Increased use of clean energy technologies
2. Reliable, affordable provision of energy to consumers
3. Ability to retain state regulatory authority over key jurisdictional elements
The two overarching energy policy priorities (numbers one and two above) are not mutually exclusive, and many states are pursuing both policy priorities simultaneously. Some states may lean more towards one overarching goal or the other. Ultimately, it is up to the states to individually consider their respective weighting of each policy priority in considering energy market constructs and how those might assist in meeting that state’s energy policy priorities. States will also need to review the specifics of any market proposal that comes before them, as different market designs may influence and change the generic rankings included in these scorecards.
States can also employ these scorecards to consider the potential impact on state regulatory authority of the various market constructs and how those impacts might be weighed against achieving a state’s energy policy goals. As with the overarching energy policy priorities, it is ultimately up to each state to weight and prioritize the anticipated benefits of a market construct with the potential impacts to state authority. The Lead Team also identified several ways that states can improve their market experiences and retain authority, particularly under an RTO market construct. The specifics of a market proposal, and of an individual state’s existing position, will be important for states to consider in evaluating how a specific proposal might impact state authority.
In sum, the scorecards provided generalized information regarding the potential achievement of overarching state policy goals and potential impacts to state authority. As such, the scorecards are intended to serve as a high-level tool of directional indicators for states as they individually and jointly evaluate options around their energy futures, but states will need to conduct more detailed analyses to evaluate specific market proposals that may come before them…