What's Happening in Energy highlights the most interesting findings from public utility commission filings.
Read at your leisure and choose your own adventure — skim the surface, or dive deeper with linked filings and Halcyon's suggested queries. Here is a Halcyon query of the week to start you off:
What's Happening in Energy — Mar 20
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In Texas, ERCOT is deliberating on “Planning Guide Revision Request” 144 (PGRR144), which would establish the procedures for large load customers to submit modeling data showing that their loads do not cause system instabilities. Yes, it’s an establishment of procedures to submit data to show something…but sometimes, very conditional-sounding or preliminary language indicates something very important
Halcyon angle: Halcyon now ingests ERCOT Revision Requests (RR) including: Nodal Protocol (NPRR), Planning Guide (PGRR), Nodal Operating Guide (NOGRRs), Other Binding Documents (OBDRR), and more. Each request number has its own profile similar to state commission docket profiles. Track each one the same way you would track a PUC docket by clicking the “Alert” button in the top right of the profile.
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In California, CAISO’s “Large Load Decision Tree” strawman provides large load customers pathways to participate in the market: supply-side and demand-side. The differences are important and impact a project’s costs and timelines. We asked Halcyon to explain this construct, defining acronyms and jargon along the way (CAISO presentation–decision tree on page 24).
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In Michigan, DTE Gas is seeking a $237.5 million rate increase (docket profile), with multiple parties submitting testimonies including challenges to specific proposed expenditures. We queried Halcyon to list the recommended disallowances by party and summarize the justifications provided. Here are a few interesting points we discovered:
CUB included the following chart to support reducing the inflation factor for operations and maintenance expenditures, stating that historical O&M costs have remained relatively stable despite high inflation.
Halcyon angle: Sometimes, we need to refine queries to get a more targeted response. Check out the two iterations of the query that we used to surface the information above: Query 1 and Query 2. This is a normal part of the Halcyon workflow. Notice how each response homes in on different documents within the docket based on the query. Click “Refine Query” in the bottom left to experiment with your own iterations. For example, you could ask for Halcyon to summarize the perspectives of the City of Ann Arbor and the Retail Energy Supply Association.
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At the FERC, Louisiana LNG filed a variance request to nearly double daily truck deliveries to its Woodside LNG project – from 320 to 640 per day (9,300 to 18,600 per month). Why? The company cites a shift away from modular construction as the primary driver, with more work now performed onsite, requiring additional civil work, earthwork, foundation preparation, and engineered fill material than originally anticipated.
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In MISO, materials from the upcoming System Planning Committee of the Board of Directors meeting give an illustrative snapshot of the generator queue (presentation). MISO’s Phase 1 2025 study process, which began this year and is expected to be completed by the board meeting on March 24th. That would make it the fastest study phase on record.
Additionally, in 2025, 10.7 gigawatts (GW) of nameplate capacity was added to the system. This equates to 5.1 GW of accredited capacity–the estimated capacity of the mix of resources during critical hours. That is the most annual accredited capacity in MISO’s history (see chart below!).
Like most system operators, MISO’s generation queue is mostly solar and storage. However, its Expedited Resource Addition Study (ERAS) process, which would “accelerate approval of critically needed resources," consists mostly of gas.
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In Massachusetts, a hearing examined the climate compliance plans (CCP) of five gas utilities (hearing transcript). Here’s how the gas utilities are implementing the CCPs. Utilities are also incorporating different thresholds into their decision making on whether to pursue decommissioning. The response indicated that utilities are focused on “strategic” opportunities for decommissioning. That brought us to this key excerpt from the transcript from Unitil (a gas and electric utility with over 100,000 customers in the Northeast region):
“When we say "strategic conversions,"they become strategic when there's an opportunity to decommission gas -- which, again, is going to be limited to cases where there's segments that maybe need to be replaced and there are no downstream systems that are going to be negatively affected and the cost of decommissioning is less than the cost of electrification and any electric-system upgrades that might be required. So looking for opportunities where there's excess capacity on the electric system, and also pending work or replacement needs on the gas system would present opportunities to electrify.”
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In Utah, Rocky Mountain Power is navigating the new Large Load Act which requires buyers with over 100 megawatts of demand to ensure their costs do not shift to other ratepayers (read overview of Act). In the first contract submitted under the new legal framework, Rocky Mountain Power and two other signatories (the Utah Division of Public Utilities (DPU), and the Office of Consumer Services (OCS)) reached a settlement agreeing that the large load service contract (LLSC) will:
The stipulation requests a Commission decision by March 20th.
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In Wyoming, Black Hills Energy (BHE) applied for a Certificate of Public Need and Necessity (CPCN) to construct a 230 kV substation and associated tie line facilities to interconnect a 365 MW hybrid solar and storage project (docket profile). BHE also entered into a Power Purchase Agreement with the generator (TGE Wyoming 225 LLC) to pass along to a Large Power Commercial Service Customer. The total cost of the project is estimated at $11.3 million.
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In SPP, an update on market performance in February 2025 reveals the consequences of forecast errors (RTO Marketplace Update). On February 24th, a sudden drop in wind generation combined with a higher-than-forecasted load caused real-time prices to spike to over $1,500/MWh. Here’s an excerpt from the notes on the presentation:
“Wind forecast was doing very well until around 5pm where it took a sharp downturn, about 1GW more severe than short term forecasts were able to capture. Load was above forecast by nearly 1.4GW, and was high throughout the afternoon. Headroom at 440 was 8.2GW, dropping to 4.8 by 540.”
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In FERC, PJM’s Co-Located Load Tariff Revisions have inspired many comments disputing PJM’s shift from using the "point of interconnection" to the "point of change in ownership" to define co-located load and PJM’s proposed 50-MW materiality threshold for BTMG is unsupported and discriminatory. Here is a summary of selected comments from Constellation, Advanced Energy United / SEIA, and the PJM Industrial Customer Coalition (and others). (docket)
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Halcyon Team Query of the Week
ERCOT's NOGRR 282, initiated last year to address reliability risks from rapid data center and cryptocurrency mining growth, establishes frequency and voltage ride-through requirements for Large Electronic Loads. This summary addresses ERCOT's responses to comments from AEP, the Data Center Coalition (DCC), and the Dynamics Working Group, as well as the DCC's opposition to the rule's "rapid, retroactive" implementation.
Public Comment Excerpt(s) of the Week
- Overnight (third-shift) gas emergency dispatch routinely staffed with a single dispatcher.
- Multiple incidents where that one dispatcher fell asleep on duty…
- No updated, realistic written procedures or training materials for dispatchers…
- A punitive culture where raising safety concerns or asking basic questions about policies and accommodations leads to discipline or termination.”
To this, Piedmont and Spire (the “Joint Applicants”) responded promptly: “The Joint Applicants take seriously any matters related to the safe and reliable operation of their natural gas distribution systems. The Joint Applicants are currently reviewing the substance of the anonymous filing and intend to submit a formal response to the Commission within seven (7) calendar days of the date of this letter.” (Joint Applicants reply)
Click “Alert” in the top right corner of the docket profile to track this docket and get notified when Spire and Piedmont fully respond to the comment (docket profile)
New Docket of the Week
In case you missed it, the most clicked item from last week’s WHiE