Professional Documents
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Contents
Editor’s Desk; Did Texas Get What It Deserved?
5
51 Illinois Solar for All: Providing Access to Solar for Low-Income Commu-
nities; Jan E. Gudell
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Volume 3, Number 2 5
Editor’s Desk
The above title may sound insensitive, after all over 20 people died as
a result of the ERCOT’s (Electric Reliability Council of Texas) failure to
maintain their electricity grid during mid-February 2021. In my defense,
I said Texas, not Texans. However, Texas is an organizational construct.
The problem was the fault of people, who happen to be Texans.
For the purpose of this editorial, I am going to discuss two separate
(yet related) failures. And, yes, I am going to assign some blame as I see it.
Because this is an editorial, it is my opinion (The Association of Energy
Engineers does not necessarily agree or disagree with my opinion). You are
allowed to agree or disagree as you see fit. If you wish to rebut, please do
so in the form of a Letter to the Editor. I promise to publish any (appropriate)
well thought out responses.
Part 1
A massive cold front powered through the United States in mid-Febru-
ary 2021. The cold front was forecasted and monitored as it moved its way
across Texas. As it crossed Texas, much of the power supply went offline,
while power demand spiked.
If you are not familiar with how a typical alternating-current (AC)
power grid operates, it is a system of balances. As demand increases, AC
frequency across the grid decreases (minutely). The decrease in frequency
causes power generation control systems (if capacity is available) to increase
power output (supply). Conversely, if demand decreases, AC frequency
increases. The increase in frequency causes generation control systems to
decrease power generation. The system fluctuates to maintain design fre-
quency, which is 60-Hz in the United States. Having excess capacity online
allows the system to respond automatically to maintain operation. Cas-
cade failures (e.g., grid outages) result from a failure to maintain adequate
excess capacity online. [NOTE: this explanation is an oversimplification
but should be sufficient for this editorial.]
The United States has three primary electric utility grid systems: East-
ern interconnect, Western interconnect, and the Texas interconnect. Most,
6 International Journal of Energy Management
but not all, of Texas is on the Texas interconnect, now known as ERCOT.
Currently, the Texas population is around 29 million people. ERCOT
serves about 26 million customers within Texas. Why does most of Texas
have their own electric grid system? Basically, it starts as a result of the
Federal Powers Act of 1935. The Federal Powers Act gave the federal gov-
ernment the authority to regulate the transfer of electricity between the
states. Texas created the Texas interconnect system in 1941. The Texas
interconnect system connects multiple electric utilities within Texas. How-
ever, to avoid federal regulation, the Texas interconnect does not allow any
export of electricity across the Texas border.
During 1965, the United States experienced its worst power outage in
the nation’s history (Side Note: this power outage did not impact Texas).
As a result of the power outage, the United States, under the authority of
the Federal Powers Act, issued new regulations to improve and ensure the
reliability of the nation’s power grid. However, the Texas interconnect is
not subject to regulation under the Federal Powers Act. The new federal
regulations did, however, prompt the Texas legislation to form ERCOT
in 1970.* ERCOT became the first of nine independent system operators
(ISOs) within North America.
The Texas legislature and the Public Utility Commission of Texas
(PUCT) have jurisdiction over activities conducted by the Electric Reli-
ability Council of Texas (ERCOT). ERCOT is governed by a board of
directors. While ERCOT is responsible for grid operations, it does not
control power generation. Generation is provided by the power producers
and electric utilities (e.g., investor-owned utilities, municipal utilities, rural
electric cooperatives, private power producers, etc.) within Texas.
The Texas interconnect is a summer peaking grid. This is not surpris-
ing, if you have ever lived through a Texas summer, the heat and humidity
can be brutal. Air conditioning, driven by high heat and humidity, drives
Texas peak electric demand. Even though Texas is a significant producer
of natural gas, most winter heating in Texas is powered by electricity (heat
pumps and electric resistance heaters).
Prior to February 2021, the Texas grid peak was ~78 GW with 17%
reserve margin (ERCOT News Release, May 13, 2020). The prior winter
peak was 65.9 GW on January 17, 2018 (ERCOT News Release, February
11, 2021).
*www.ercot.com
Volume 3, Number 2 7
*There were also cold weather events in 1983, 1989, 2006, 2008, and 2010, but 1989 was the worst
and most comparable to 2011.
**https://www.ferc.gov/sites/default/files/2020-04/08-16-11-report.pdf
8 International Journal of Energy Management
Basically, nothing.
You might think that this time (2021) will be different. People died.
Texas citizens suffered; some are still suffering. Texas politicians are point-
ing fingers and contradicting themselves in their accusations. The Texas
governor and pundits on Fox News (and other conservative networks) tried
to blame the Green New Deal (which, by the way, does not exist) and the
growth in renewable energy sources, which is a sad lie. Yes, some ERCOT
managers and directors have resigned, some have been fired. There is
(again) calls for more weatherization of the power plants, transmission sys-
tems, and interconnects. Right now, it is all thoughts and prayers. Unless
the voters call for action, the Texas government will likely stall until the
public’s attention moves onto the next shiny object. The bottom line is that
had Texas learned from history, this event may likely have been avoided.
Unless action is taken, it will likely happen again.
Part 2
Deregulation of the electric grid and electricity market in Texas began
in 1995 (Texas Senate bill 373). The retail electric utility market in Texas
began the deregulation process in 1999 (Texas Senate bill 7). By 2002, it is
estimated that 85% of Texas power consumers have some level of choice
in retail electric providers. Since 2002, more than 5.6 million Texans have
participated in the deregulated market (www.saveonenergy.com).
The promise of the deregulated market was that wholesale and con-
sumer costs would decrease sufficiently to justify the consumer taking on
the increased risks and the cost of risk mitigation. In Texas, this may not
have been the case (see Figure 1). A 2009 report* by the Cities Aggrega-
tion Power Project, concluded that Texans in a deregulated market were
paying more and getting hit with bigger price increases. Similarly, in a
2014 report** by the Texas Coalition for Affordable Power concluded that
residents in the Texas deregulated markets generally pay higher electricity
costs than residents in non-deregulated*** Texas markets.
The Association of Energy Engineers has taught seminars on deregu-
*The History of Electric Deregulation in Texas, Cities Aggregation Power Project, 2009. www.tcaptx.
com/downloads/HISTORY-OF-DEREGULATION.pdf.
** Deregulated Electricity in Texas, Texas Coalition for Affordable Power, 2014.
http://tcaptx.com/wp-content/uploads/2014/02/TCP-793-Deregulation2014-A-1.7.pdf
*** Areas around Austin and San Antonio have opted out of retail deregulation and, as a result, have
experienced the level of escalation in utility costs compared to deregulated areas.
Volume 3, Number 2
ABSTRACT
The sample size chosen for the RBSA allows benchmarking of energy
use within households at sufficient detail to assess the progress of chang-
es in energy efficiency and home characteristics within the region. This
study informs future energy planning efforts as well as energy efficiency
utility programs by the region’s utilities, the Energy Trust of Oregon
(www.energytrust.org) and BPA (www.bpa.org).
NEEA also conducted the Commercial Building Stock Assessment
(CBSA), a regional study of the energy use in commercial buildings,
by collecting detailed information on building characteristics, installed
Volume 3, Number 2 17
Figure 1. Illustration of the Change in Daily Lighting Load Homes in the 1980s
to Homes in the RBSA. (Source: Northwest Power and Conservation Council,
used with permission)
Volume 3, Number 2 19
teristics data from the RBSA and CBSA. When analyzed together, this
information can help explain not only how much energy is consumed,
but the reasons energy is consumed.
Contractors
In 2017, the Working Group created a subcommittee to develop a
Request for Proposals (RFP) to administer HEMS. At the recommenda-
tion of the Working Group, the Steering Committee approved Evergreen
Economics, Portland, Oregon as the HEMS contractor.
In 2018, the Working Group developed another RFP to administer
CEMS. The Steering Committee approved the Working Group’s recom-
mendation of DNV GL as the CEMS contractor.
*The equipment deployed in HEMS allows capture and storage of 1-minute data to enable a
more granular analysis of equipment electricity use patterns and fault detection (corrupted data).
One-minute data are aggregated into 15-minute data for long-term public data archiving.
22 International Journal of Energy Management
The contractor used the existing 2016–17 RBSA study as the prima-
ry sample frame. This improved cost-effectiveness by utilizing detailed
information about the homes and appliances of metering study partici-
pants, rather than recruiting homes for metering from the general pop-
ulation. Because the end-use equipment is known in each RSBA home,
the contractor was able to efficiently recruit homes with one or more of
the six target end uses.
Comprehensive sampling and recruitment plans were developed by
**The first law of ELCAP is: “You can always recover from bad analysis but never from bad data.”
This provided the inspiration to include a quality assurance plan in the EULR project.
Volume 3, Number 2 23
the contractor and approved by the Working Group and Steering Com-
mittee prior to program launch. The sampling plan assured a represen-
tative allocation of homes for the target end uses and across the climate
zones of the Northwest. The sampling plan recognized the significant
challenge in recruiting homes with ductless heat pumps and heat pump
water heaters, as there are relatively few homes in the region with that
equipment installed.
Metering Equipment
Up to 20 circuits and the whole home are metered using current
transformers (CTs) that are installed in the home’s service panel and con-
nected to the data logger. Additionally, the indoor temperature is mea-
sured in all homes, and the refrigerant/vapor line (surface) temperature
is measured in homes equipped with heat pumps as a surrogate for the
operating mode of the heat pump (e.g., when the unit is in defrost mode).
Homes with supplemental heat (e.g., gas fireplaces) have a second indoor
temperature set nearby the supplemental heat as a surrogate of when
that supplemental heat is used. Exterior temperature is monitored for
homes where there are no nearby weather stations to acquire exterior
temperature data.
The metering configuration is shown in Figure 2. The pre-assembled
metering package (labeled, “In the Box”) is powered by a 110V dedicat-
ed circuit. It includes:
• HVAC:
- Rooftop units
- Heat pumps
- Electric resistance heating
Metering Equipment
The metering suite is composed of several components which,
depending on site-specific circumstances, will be installed for different
functions and at different quantities. These site-specific circumstances
include locations of building panels and unit disconnects, cellular recep-
tion, mounting options for metering equipment, and how the data logger
will communicate locally with the cellular modem. The key components
of the metering suite are:
Volume 3, Number 2 27
• An eGauge energy meter that acts as the power metering device, data
logger, and web server to provide user interface and push kilowatt
data to the contractor’s server. The eGauge energy meter requires
Wi-Fi or cellular connection for server communications.
with permission)
Volume 3, Number 2
29
30
International Journal of Energy Management
Figure 6. Whole Home Load Profile by End Use Before and During Covid-19
(Source: Evergreen Economics, used with permission)
31
32 International Journal of Energy Management
CONCLUSION
Figure 7. Home Range Burner Average Hourly Load: Weekday and Weekend,
Before and During Covid-19. (Source: Evergreen Economics, used with per-
mission)
33
34 International Journal of Energy Management
data from across the Northwest before, during and after the COVID-19
pandemic.
In the meantime, 15-minute interval data from HEMS can be
downloaded free of charge on NEEA’s website: https://neea.org/
data/end-use-load-research/hems.
References
(ELCAP 1984). End-use Load and Conservation Assessment Program Overview: Objectives and
Methods. Bonneville Power Administration, Portland, Oregon. July 1984.
(RBSA 2019). Residential Building Stock Assessment II Single Family Homes Report. Northwest
Energy Efficiency Alliance, Portland, Oregon. March 2019.
≥
AUTHOR BIOGRAPHIES
Graham Parker CEM, CEA, is the President of Graham Parker
& Associates, LLC. Mr. Parker is a retired former Emeritus staff at the
Department of Energy’s (DOE) Pacific Northwest National Laboratory
(PNNL). In his nearly 46 years at PNNL, he focused on the design, con-
duct and analysis of the evaluations of the performance of buildings
and equipment. He has worked with domestic and international clients
to develop and promulgate energy policies, improve building energy
and water efficiency and deploy new and emerging technologies.
Mr. Parker is a Chemical Engineer graduate of Oregon State Uni-
versity. He is a Fellow in the Association of Energy Engineers (AEE)
and a member of the AEE Hall of Fame. He is a Certified Energy
Manager and Certified Energy Auditor. He is a member of the Work-
ing Group for the Northwest End-Use Load Research Project and
serves on the Northwest Power and Conservation Council’s Regional
Technical Forum. He is the 2005 recipient of the Presidential Award
for Leadership in Federal Energy Management and the 2017 recip-
ient of the Tom Eckman Lifetime Achievement Award for Energy
Efficiency.
Analysis for Seattle City Light, where he led five integrated resource
plans (IRPs). He also was Director of the Electric Transmission and
Western Energy Services at Cambridge Energy Research Associates,
where he consulted on regulatory policy, regional transmission organi-
zation market design, resource planning, renewables development, and
institutional investments. At PacifiCorp, he managed Corporate Stra-
tegic Planning, and worked in the Economic Development and Load
Forecasting Departments. His thesis for a Masters in Agricultural and
Resource Economics was selected for presentation at a National Acad-
emy of Sciences Annual Meeting.
36 International Journal of Energy Management
U.S. Department of
Energy Solar Decathlon*
Amanda R. Kirkeby
Zachary A. Peterson
ABSTRACT
INTRODUCTION
*Based on a paper presented at the 2020 Virtual AEE World Energy Conference.
Volume 3, Number 2 37
COMPETITION BACKGROUND
Architecture
Elegant, yet functional architecture positions a building for suc-
cessful market acceptance. The Architecture contest evaluates student
submissions in their ability to employ architecture to marry aesthetics
with effective building science, energy efficiency, occupant experience,
comfort, natural ventilation, energy production, and resilience.
Engineering
Efficient building design is achieved through integration of thought-
ful engineering. The Engineering contest considers the informed selec-
tion and design of all building envelope components and building
Volume 3, Number 2 39
Market Analysis
Providing effective zero energy alternatives that are financially fea-
sible is essential to successful adoption. The Market Analysis contest
evaluates an understanding of the target market with considerations
toward affordability, likelihood of adoption by intended occupants, and
cost-effectiveness of the design. This includes detailed financial analy-
sis of construction materials, with attention to life-cycle costs. Success-
ful designs also exhibit flexibility and adaptability to changing needs
of occupants to ensure the building meets the demands of the target
market.
Integrated Performance
To emphasize the importance of an integrated design approach,
40 International Journal of Energy Management
Occupant Experience
Human-centric design is essential to successful adoption and uti-
lization of a high-performance buildings. The Occupant Experience
contest places the human experience at the center of the design strat-
egy, evaluating how the building optimizes occupants’ quality of life
while meeting the energy performance goals. This includes strategies
for efficiency, comfort, health, and safety that address operational
expectations of consumers and thoughtful selection of technologies
and appliances that are integrated into the overall design.
Energy Performance
Effective whole-building energy analysis and decision-making is the
foundation for energy performance. The Energy Performance contest
evaluates reduction of whole-building energy consumption, ability to
generate clean energy that is needed onsite, and interaction with local
grid operations. As a central component of the competition criteria,
Volume 3, Number 2 41
Presentation
Innovative design is insufficient on its own; presentation quality can
dramatically affect consumer perception and the likelihood of inno-
vation being adopted. The Presentation contest evaluates the student
teams on their ability to effectively communicate their design strategies,
both verbally and visually. This contest challenges the students develop
essential communication skills to convey value to a diverse audience
and inspire future professionals, incumbent industry leaders, and the
public to pursue energy efficiency and renewable energy opportunities.
INDUSTRY IMPACT
Figure 1. Interior Rendering from Purdue University of the Zero Energy James Cole Elementary School Designed
for Tippecanoe School Corporation. [Image Credit: Purdue University Solar Decathlon team]
43
44 International Journal of Energy Management
Figure 2. Schematic Diagram of the SOURCE, the Solar Urban Center, Washington Alexandria Archi-
tecture Center’s Restoration of a Historic Building in Downtown Alexandria. [Image Credit: WAAC
Solar Decathlon team]
45
46 International Journal of Energy Management
CONCLUSION
System Design in
the University of
District of Colum-
bia’s Proposal for
Modernizing the
Henry Smothers
Elementary School.
(Image Credit: UDC
Solar Decathlon
Team)
Volume 3, Number 2
47
48 International Journal of Energy Management
References
[1] “Global Energy Consumption Driven by More Electricity in Residential, Commercial
Buildings.” U.S. Energy Information Administration (EIA), 21 Oct. 2019. Available at
www.eia.gov/todayinenergy/detail.php?id=41753 (accessed January 27, 2021).
[2] U.S. Department of Energy Race to Zero Student Design Competition: 2014 Results. U.S.
Department of Energy Office of Energy Efficiency and Renewable Energy. Available at
https://www.energy.gov/eere/buildings/2014-results (accessed January 27, 2021).
[3] U.S. Department of Energy Solar Decathlon: 2021 Design Challenge Teams. U.S. Depart-
ment of Energy Solar Decathlon. Available at https://www.solardecathlon.gov/2021/
design/challengesteams.html (accessed January 27, 2021).
[4] U.S. Department of Energy Solar Decathlon 2021 Design Challenge Rules. PDF. July
2020. Available at https://www.solardecathlon.gov/2021/assets/pdfs/sd-designchal-
lenge-rules.pdf (accessed January 27, 2021).
[5] U.S. Department of Energy Solar Decathlon 2020 Design Challenge Results. Project
Summary: Purdue University. PDF. April 2020. Available at https://www.solardecathlon.
gov/2020/assets/pdfs/ES_Second%20Place_Purdue%20_Univeristy_Project_Summary.
pdf (accessed January 27, 2021).
≥
AUTHOR BIOGRAPHY
Amanda R. Kirkeby is an energy engineer at the National Renew-
able Energy Laboratory (NREL) in the Integrated Applications Cen-
ter’s Applied Engineering group. She supports the U.S. Department
of Energy Solar Decathlon Design Challenge and the development of
resources for high-performance laboratories and other building-sys-
tems-related initiatives. Amanda Kirkeby has a bachelor’s in physics
from Middlebury College, Vermont, and was a member of the Mid-
dlebury’s winning Zero Energy Elementary School Team in the 2018
Race to Zero Student Building Design Competition (now the Solar
Volume 3, Number 2 49
ABSTRACT
The Illinois Solar for All (ILSFA) Program provides access to the
clean energy economy for low-income communities through incentives
that make solar installations more affordable and result in measurable
savings for participants. Launched in 2019, this program creates oppor-
tunities for low-income households to benefit from rooftop solar onsite.
It also provides incentives to install solar on non-profit and public facili-
ties, and to develop community solar installations in the state of Illinois.
The Future Energy Jobs Act (FEJA), the clean energy legislation that
mandated this program, requires that tangible economic benefits flow
to program participants, that incentives are provided to projects in envi-
ronmental justice communities, and that job training opportunities are
provided. The ILSFA Program also provides extensive consumer protec-
tions and a project review process that validates site suitability to ensure
energy and renewable energy credit (REC) production and low-income
participant benefits. This article will include an overview of FEJA and
ILSFA programs, including program development and progress. The
discussion will include how the lessons learned in the first two years were
incorporated in the programs for continuous improvement.
The Future Energy Jobs Act (FEJA) (Senate Bill 2814) is one of the
most significant pieces of energy legislation to pass the Illinois Gen-
eral Assembly. It offers a variety of features to strengthen and expand
energy efficiency and renewable energy markets and services in Illinois
*Based on a paper presented at the 2020 Virtual AEE World Energy Conference.
52 International Journal of Energy Management
while also providing funding to establish job training programs. The law
became effective June 1, 2017.
FEJA directs a budget from utility companies of approximately $180
million annually to procure renewable energy produced in Illinois. This
requires at least 4,300 megawatts of new solar and wind power1—enough
electricity to power millions of homes—to be built in Illinois by 2030.
Most new solar development in Illinois occurs through the purchase
of renewable energy credits (RECs) by the Illinois Power Agency (IPA),
the state office in charge of managing large investor-owned electric util-
ity power purchases and ensuring that such purchases meet the state’s
Renewable Portfolio Standard2, which mandates that 25 percent of retail
power comes from new renewable sources.
The passage of FEJA enabled the development of two new state-
wide solar programs: The Adjustable Block Program (ABP), also known
as “Illinois Shines,” and Illinois Solar for All. Both programs are over-
seen by the IPA, the chief distinction between them being the ABP is
market rate, while Illinois Solar for All supports low-income customers,
non-profits and public sector entities. While there are numerous market
rate programs across the U.S., there are comparatively fewer low-income
programs. This article looks at Illinois Solar for All.
The Illinois Solar for All (ILSFA) program provides greater access
to the clean energy economy and solar energy to low-income house-
holds, non-profit organizations, and public facilities across the state
through incentives that help make solar installations more affordable.
ILSFA launched in May 2019, accepting applications for new solar proj-
ects in Illinois. Approved vendors—the entities that develop solar proj-
ects—submitted their first applications for ILSFA’s three sub-programs:
1New renewable energy includes wind and photovoltaic projects energized after June 1, 2017, or
for wind, “within 3 years after the date the [Illinois Commerce] Commission approves contracts
for subsequent delivery years.” See the Illinois Power Agency Act (20 ILCS 3855) section (c)(1)(C)iii
https://www.ilga.gov/legislation/ilcs/ilcs5.asp?ActID=2934&ChapterID=5
2FEJA helped repair Illinois’ “broken Renewable Portfolio Standard. See the Illinois Power Agency
3See the table of maximum income for households to be eligible for Illinois Solar for All: https://
www.illinoissfa.com/app/uploads/2019/02/0219-ILSFA-income-chart-v4.pdf
4See the ILSFA REC prices at https://www.illinoissfa.com/renewable-energy-credit-prices/
54 International Journal of Energy Management
Table 2.
Low-Income Distributed Generation Incentive (5+ unit buildings) ($/REC)
of the IPA Act. Finally, the potential additional funds from the renewable
resources budgets of the utilities pursuant to Section 16-108(k) of the
Public Utilities Act. Table 5 depicts the published project budgets for the
first two years of the program, exclusive of administration costs. Unal-
located funds within a sub-program from each program year are rolled
over to the following program year.
APPROVED VENDORS
All ILSFA projects are developed by approved vendors who are vet-
ted and approved by the program administrator. Approved vendors are
the contractual counterparty to either the IPA or an Illinois electric util-
ity for renewable energy credits (RECs) purchased through ILSFA. As
such, Approved Vendors are the entity receiving payments from the IPA
or utility for REC delivery as contract obligations are met.
The approved vendor model helps to ensure the accuracy and qual-
ity of information submitted to the program administrator and reduce
the administrative burden on the contractual counterparties. Approved
vendors are required to work within prescribed guidelines that govern
their interaction with the marketplace and program participants. These
requirements ensure consumers are protected against unsafe and unfair
business practices and are designed to minimize risk to participants.
Approved vendors are first registered in the Adjustable Block Pro-
gram (ABP), and then ILSFA. Once approved in the ABP, approved
vendors can apply to ILSFA. REC contracts for both programs are pro-
cessed by the ABP program administrator, thus going through ABP regis-
tration process first ensures that approved vendors are screened for their
ability to legitimately conduct business in Illinois and legally act as the
counterparty for the REC agreement. By completing registration in the
ABP, approved vendors have access to the ABP target market and fund-
ing. Currently there are 52 approved vendors in ILSFA.
CONSUMER PROTECTIONS
Standard Disclosures
Approved vendors must complete standard disclosure forms and
provide these to participants prior to contract execution. Standard dis-
closures include system equipment and components, warranty, financial
terms, total costs and fees, projected energy production and savings, and
other important information. Disclosures for Low-Income Distributed
Generation projects must be presented to participants at least 7 days
prior to contract execution, and the participant has 7 days after contract
execution to cancel.
Financial Requirements
Financing amounts, terms, and conditions must be based on an
58 International Journal of Energy Management
Marketing Requirements
All approved vendors must adhere to comprehensive guidelines that
govern the information used in marketing materials and the behavior of
vendors in their interactions with participants. Marketing requirements
include the use of standardized brochures that must be presented to all
participants.
Quality Workmanship
Approved vendors are fully vetted and must adhere to technical
system requirements to ensure efficient system performance, as well as
adhere to all local ordinances governing building codes, permitting, and
zoning. In addition, there are requirements that approved vendors meet
minimum site suitability guidelines and must allow all installations to
undergo photo and onsite inspections by program administrator techni-
cians.
Performance Assurance
Five percent collateral as a percent of REC contract value must be
posted for a system within 30 business days of project approval. Under-
performance by any system in either REC deliveries or community solar
subscriptions can trigger a collateral drawdown.
In each program year (PY), the ILSFA program offers one or more
project submission window(s) to allow for project review and selection.
When a sub-program is oversubscribed—when incentive values for sub-
mitted projects are higher than the available budget in a given program
year—the program administrator will apply a project selection protocol
to select projects most closely aligned with program goals. If the incen-
tive value of eligible projects submitted during the project submission
Volume 3, Number 2 59
ELIGIBILITY REQUIREMENTS
Income Eligibility
In the DG and community solar sub-programs participants are Illinois
households whose annual income must be 80% or less of area median
income. Other than an anchor tenant, which is not a low-income house-
hold, all community solar subscribers must be low-income households.
DG Projects
DG projects must be installed behind a customer’s meter and are
used to offset the load of one or more qualifying residential households
occupying that property. An example DG project would be a 5-kW system
on the roof of a residential home, or a 30-kW system on a multi-family
building off-setting the common-area meter load.
QUALITY ASSURANCE
5Low-income communities are defined as census tracts having a majority (50% or greater) of house-
holds at 80% or less of AMI.
6Environmental justice communities are identified through a methodology that multiplies the aver-
age of exposures and environmental effects with average socioeconomic factors. The calculation
identifies the top 25% of qualifying census block groups across the state.
Volume 3, Number 2 61
• System
– One-line drawing
– Alternating current (AC) and direct current (DC) equipment
make and model, quantities, ratings cut sheets/UL listings
– Layout
– AC and DC capacity
– Structural and BOS sheets
– Interconnection agreement
– Annual kWh production
– Onsite inspection
• Site and Customer Info
– Photos of AC and DC equipment installation location
– Photos of roof surface, or ground mount location and surround-
ings
– Aerial views
– Shading analysis report
– Assessment report
▪ roof condition
▪ electrical system
▪ building structure
▪ permitting
– Billing/usage history
– Customer contract
– Site control
– Disclosure forms
– Community linkages
– Customer savings impact.
If, for example, deficiencies are identified in the site review, say, a
roof in poor condition, the approved vendor must present a mitigation
plan to address the issue(s) before the project is approved. Or, if the site
has obstructions (chimneys, rooftop units (RTUs), vents, parapets, near-
by buildings and trees) that would cause shading and thus reduce power
generation, the vendor manager ensures that project shading analysis
includes such obstructions to properly validate the system design and
REC production estimate. It would not be acceptable to permit a proj-
ect to move forward where the roof is in poor condition (advanced age,
visible ponding, curled shingles, cracks, etc.) without a clear plan demon-
strating how the roof will be repaired. The review process helps ensure
the system will produce for the contracted 15-year REC delivery term at
the projected REC quantities.
After the system is completed, approved by the authority having
jurisdiction and local utility, the program administrator conducts a visual
inspection of the project and reviews final documentation. Projects satis-
fying final requirements are authorized to submit an invoice for payment.
PROGRAM RESULTS
At the time of writing this article, the program has completed 2 full
program years, and is nearly complete with a third.
LESSONS LEARNED
The first year of ILSFA was a learning curve for all involved with the
program. Solar, while being an increasingly popular generation technol-
ogy, is still new to most people in Illinois. The rules that govern Illinois
Solar for All are complex and require approved vendors to make a com-
mitment to study them, to ensure the projects they develop are eligible.
Ultimately, projects must be sold to participants, who are unfamiliar with
66 International Journal of Energy Management
the complexities of Illinois Solar for All. Approved vendors have plen-
ty of work to do to assemble an eligible project. There are numerous
files and pieces of information that must be gathered and provided to
the program, each validated by program administration. This can be a
daunting and complicated process.
We found that the process of identifying required information
through review of the Approved Vendor Manual is difficult for many
approved vendors because the requirements are laid out in different sec-
tions, and the language in the manual can be difficult to follow. This can
lead to additional effort following up on items that are unclear or missing
from the project applications.
To make it easier for approved vendors to know what they need to
submit on their project applications, the program administration team
developed a Part I submissions guideline document, which functions as a
notated checklist, giving approved vendors clarifications on what is need-
ed to submit an application, all in one place. This helps approved ven-
dors save time and effort. In addition, the program administration team
produced a series of short training videos, covering a variety of practical
topics, to make things easier. The program administrator will continue to
develop helpful resources and enhancements that anticipate and respond
to approved vendor needs.
Volume 3, Number 2 67
≥
AUTHOR BIOGRAPHY
Jan Gudell, CEM, PV Associate (NABCEP), has 16 years of
renewable energy and energy efficiency experience. He is a senior solar
program manager at Elevate Energy, a non-profit organization that
designs and implements programs to reduce costs and protect people
and the environment. In addition to being a Certified Energy Manager
(CEM), Jan Gudell is also a PV Associate certified by the North Amer-
ican Board of Certified Energy Practitioners (NABCEP). Jan earned
a bachelor’s degree in science and technology studies at Cornell Uni-
versity and a master’s degree in environment and resource policy at
Tufts University. Jan Gudell can be reached via email at jan.gudell@
elevateenergy.org.
68 International Journal of Energy Management
ABSTRACT
INTRODUCTION
*Based on a paper presented at the 2020 Virtual AEE World Energy Conference.
Volume 3, Number 2 69
energy sources. Since evidence suggests that returns to scale will be less
important for these renewables [4], likely leading to an increasing rate of
growth of new generation projects entering the market, and since fixed
costs are a much more important part of their total costs, the degree of
competitiveness of wholesale markets will be key to incorporating these
new sources of electricity in a competitive manner. At the same time,
given the need for flexibility in incorporating these fuels, whose supply
can vary substantially from minute to minute, markets are likely to devel-
op a number of financial products, and increase demand for ancillary
services, leading to increased opportunities for market manipulation.
All of these factors mean that open, transparent, and competitive
wholesale markets with low barriers to entry and strong safeguards
against market manipulation will be key to satisfying world demand for
electricity in a low-coast, efficient way. The independent market moni-
tors are responsible for detecting attempts to exercise market power and
fraudulent behavior; evaluating market performance, detecting and sug-
gestions corrections for market design imperfections; analyzing transmis-
sion and generation blackouts, and assessing market participants’ behav-
ior. Given this description, the role played by the independent market
monitor, and the degree to which it is able to guarantee that wholesale
markets display these characteristics, is likely to be a linchpin of efforts
to integrate renewables.
BACKGROUND
Room only in the year after it published its order 2000, requiring the
creation of Regional Transmission Organizations (RTOs) [5].
Early efforts were less than impressive. In fact, the U.S. General
Accountability Office, then the General Accounting Office, noted in a
2002 study,
“To date, FERC’s initiatives to monitor competitive markets have
served more to help educate FERC’s staff about the new markets
than produce effective oversight efforts. For example, the agency’s
Market Observation Resource room makes a substantial amount
of market data available to staff in a readily usable format; how-
ever, this information has not yet been used to initiate an enforce-
ment action or to confirm or refute a problem identified elsewhere
in the agency.” [6]
Increasing evidence that deregulated markets needed more robust
monitoring efforts, notably the California energy crisis of 2001-2002 led
to a considerable ramp up of market monitoring efforts, including the
establishment of FERC’s Office of Market Investigations and Opera-
tions, now the Office of Enforcement. This crisis also gave impetus to
efforts to establish market monitor efforts at the RTOs, part of their
responsibility under FERC 2000. [7]
energy market oversight, and for analytics and surveillance. Their inter-
nal and external reports present the state of energy markets, analyze
trends, provide early warning on market issues, and makes recommen-
dations on corrective actions to the FERC Commission based on their
findings. [8]
In 2018, Division of Analytics and Surveillance surveilled over 36,000
hub and pricing nodes within the six ISO/RTOs and provided support
on approximately 50 investigations. In the same year, the Division of
Investigation staff opened 24 new investigations, closed 23 pending
investigations with no action and negotiated six settlements of over $149
million, including $83 million in civil penalties and over $66 million in
unjust profits; and the Division of Audits and Accounting completed 14
audits of energy companies, resulting in 209 recommendations for cor-
rective action and $185.1 million in refunds and recoveries. Finally, the
Division of Market Oversight continued analyzing market fundamen-
tals (including significant trends and developments), presented its annual
State of the Markets Report assessing significant events of the previous
year and its biannual reporting, and reached out to the filing community
to discuss potential system improvements and enhancements. [9]
In addition to its considerable resources, FERC also relies on the mar-
ket monitoring units of the RTOs, and many of the investigations and
audits mentioned above may have begun as referrals from the regional
level. In its Order 2000, FERC made no ruling or suggestion as to how
the RTOs would carry out these monitoring responsibilities, to allow for
differences in the organizational structure of RTOs. As a result, RTOs
have structured their market monitors in a way that is appropriate for
them. Thus, RTOs may establish market monitoring functions within
their organizations or outsource the function to third party providers.
At present, all of the U.S. RTOs have internal market monitors
except for PJM and MISO. A number of them, as well as PJM, also have
external market monitors. Monitoring Analytics is the market monitor
for PJM, while Potomac Economics monitors ERCOT, New York ISO,
ISO New England, and MISO. While RTO market monitoring units do
not have the same power to fine (and refer for criminal prosecution in
extreme cases) that FERC does, they can modify offers ex ante if they
exceed competitive reference values. Monitors can also suspend trading
privileges for financial (non-physical) participants, and request explana-
tions of suspect behavior.[10] The independence of the market monitors
72 International Journal of Energy Management
from the RTOs is ensured by the fact that they report directly to the
Board of Directors of these institutions, as well as by the fact that they
can go directly to FERC in case of any dispute with the management of
the RTO.
In Europe, Nord Pool, which manages wholesale electricity trad-
ing throughout thirteen trading areas of Western Europe, has a similar
role to that of a US ISO. The equivalent to FERC is EU’s Agency for
the Cooperation of Energy Regulators (ACER). Market monitoring is
particularly important in the European market since energy markets in
many member countries are very concentrated: A 2015 study showed
that the market share of the largest electricity producer was greater than
50 percent in 15 European countries. [11]
In 2011 the EU adopted the Regulation on Wholesale Energy Market
Integrity and Transparency (REMIT) as their regulation for managing
wholesale markets and designated ACER as the organization authorized
to enforce REMIT. [12]
ACER works with the European Network of Transmission System
Operators for Electricity (ENTSO-E), a collection of forty-three trans-
mission operators throughout thirty-six European countries, to manage
a reliable transmission grid capable of meeting the needs of a wholesale
electricity market. ACER contains three organizations for market mon-
itoring. The Electricity Department has teams focused on market codes,
market monitoring, grid connection codes and infrastructure. The Mar-
ket Surveillance and Conduct Department has teams devoted to market
conduct, market surveillance and referrals. The Market Integrity and
Transparency Department has teams assigned for market data analysis,
market data reporting, and enforcement of REMIT. [13]
Based on its findings, ACER can issue recommendations to the Com-
mission on market rules, standards and procedures which could improve
market integrity and the functioning of the internal market. In the case it
finds suspected cases of market manipulation, it refers the case to the rel-
evant national regulatory agency for further investigation, and enforce-
ment.
In contrast with the U.S. and many other markets, mitigation options
are largely ex post. ACER lacks the ability to modify offers, and as a
result must rely on fines levied by the relevant regulatory agency ex post.
This is less than ideal, since such fines do not compensate consumers
for the wealth transfers caused by high prices after the event. For exam-
Volume 3, Number 2 73
ple, Iberdrola was fined 25 million Euros for market manipulation that
earned them 21 million Euros in profits, but total impact on demand was
estimated at 105 million Euros. [14]
In addition, ACER is not currently doing much in area of recom-
mendations due to a severe lack of personnel and budget. Furthermore,
many European Regulatory Agencies are unable to enforce REMIT
because necessary regulations have not been implemented at the nation-
al level, and although some countries have specialized market monitors,
many countries have instructed their competition offices to monitor
energy markets, and these offices often lack specialized personnel.[15]
More recently, the number of investigations into violations of REMIT
has increased, as has the scale of sanctions for non-compliance. National
regulatory agencies issued six decisions regarding market manipulations
in violation of REMIT in 2019, with fines for a variety of market par-
ticipants, including energy exchanges, gas and electricity suppliers, and
traders. [16] And in 2020, a fine of over 37 million pounds was levied by
UK’s OFGEM to the InterGen Group of companies for market manip-
ulation, the highest ever fine for a REMIT breach.[17] These results may
indicate that necessary resources are finally being applied to this task.
Turning to Latin America, market monitoring is carried out in a
number of different ways throughout the region. It is generally, but not
always, the regulatory organizations that are charged with monitoring
energy markets. In the case of Chile, it is housed under the system oper-
ator, and in the case of Mexico, the market monitor is a third party. Here
is where some of the Latin American market monitoring functions are
carried out:
tive market. In each of the 3 annual reports published so far, the moni-
tor has signaled a number of important design flaws, as well as cases in
which the actions of CENACE do not comply with existing regulations.
[21]
In Colombia, the Superintendency of Public Services (SSPD for its
initials in Spanish) has monitored Colombia’s wholesale electricity and
gas markets since both entities were created under the electricity sector
reforms of 1994. [22] However, it was not until 2006 that the SSPD
established a Wholesale Energy Market Monitoring Committee, which
was expanded into the Monitoring Unit for Energy and Gas in 2019. The
responsibilities of this newly-formed monitoring unit include develop-
ing methodologies to monitor the wholesale gas and electricity markets,
including the development of relevant indicators, and to publish infor-
mation on their functioning, with a particular emphasis on preventing
and mitigating the use of market power, and making recommendations
to allow regulators and the system operator to improve market efficiency
and competition.
With respect to electricity markets, their website contains daily
reports on the degree of concentration in installed capacity, actual gen-
eration and availability, declared availability, programmed vs. real gener-
ation, and the concentration of the price-setters (the only area in which
the unit signals market concentration). They also publish weekly and
quarterly reports, with a larger analytical component. In its most recent
quarterly report, in addition to the concentration in the generators set-
ting prices pointed out in the daily reports, analysis shows variations in
prices of the hydro generators that strongly suggest strategic pricing. [23]
The strong possibility that market participants are able to exercise this
kind of market power is a compelling argument in favor of constructing
market parameters of the type constructed by the Mexican market mon-
itor and modifying prices ex ante in response to price offers outside these
parameters.
CONCLUSIONS
toring-2016-july-1.pdf
[16] https://www.bakerbotts.com/thoughtleadership/publications/2019/may/remit-enforce-
mentintensifies
[17] https://www.current-news.co.uk/news/ofgem-finesintergen-37m-for-market-manipula-
tion-in-strong-message
[18] For an interesting discussion around the relative advantages and disadvantages of cost-
based vs. bid-based pricing, see http://www.cesworkshop.cl/archivos/5.FranciscoMun%C-
C%83oz.pdf
[19] Information obtained from a webinar: https://usea.org/event/independent-market-moni-
torsconversation-monitors-chile-and-colombia, and from email exchanges with the Chilean
presenter, José Benito Sanhueza Galleguillos, economist at the Market Monitoring Unit of
the National Electrical Coordinator of Chile.
[20] https://www.gob.mx/cre/documentos/reportes-sobreel-desempeno-y-la-evalua-
cion-del-mercado-electricomayorista
[21] These and other reports can be found here: https://www.gob.mx/cre/documentos/
reportes-sobre-eldesempeno-y-la-evaluacion-del-mercado-electricomayorista
[22] https://www.superservicios.gov.co/serviciosvigilados/energia-gas-combustible/energia/
mercado-deenergia-mayorista
[23] https://www.superservicios.gov.co/serviciosvigilados/energia-gas-combustible/uni-
dad-de-monitoreopara-mercados-de-energia-y-gas
[24] https://www.entsoe.eu/about/market/
≥
AUTHOR BIOGRAPHY
Johanna Koolemans-Beynen is Senior Program Coordinator
at the United States Energy Association (USEA), which represents the
U.S. on the World Energy Council. She coordinates USEA activities in
Colombia, India, and Honduras, under the USAID-funded Energy Util-
ity Partnership Program, focusing on the regulatory and legal framework
necessary to successfully integrate renewable energies onto the electric-
ity grid. She is also working to set up a worldwide Business Innovation
Partnership, which aims to help utilities incorporate business change
management and business process innovation principles into their grid
modernization and energy management projects.
Prior to joining the USEA she worked for various universities in
Mexico, including the Tecnológico de Monterrey, where she coordinated
on-line training at the Institute for Global Sustainability (IGS), and coordi-
nated climate-change projects at the Center for Dialogue and Analysis on
North America; and the Centro de Investigación y Docencia Económicas
(CIDE), where she taught International Economics. Her bachelor’s degree
is from Georgetown University, and her master’s from Johns Hopkins Uni-
versity (Washington D.C.): She also completed the coursework for a mas-
ter’s degree in Economics from the Colegio de Mexico.
Volume 3, Number 2 79
International
Journal of
ENERGY
aeecenter.org