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Of Polar Vortexes and PJM Price Spikes
By Judah Rose, David Gerhardt, John Karp,Frank Brock,Trisagni Sakya and Mohit Shrestha
ICF International

Executive Summary
1

As discussed in the previous Polar Vortex white papers, extremely high power prices create significant
commercial opportunities that can be partly predicted in advance and also highlight the need for careful
attention to reliability policy and planning due to changes in resource mix and market rules. These
conclusions have been dramatically reinforced by the developments of the past few days – January 20-24,
2014. Delivered natural gas prices in the east reached all-time record levels of well above $100/MMBtu,
and also well above prices in early January 2014 – one key delivered gas price was 3 times higher,
$123/MMBtu versus $40/MMBtu. Meanwhile the gas price at Henry Hub, the traditional benchmark for
natural gas prices, was less than $5/MMBtu. Indeed, while some gas prices were at record levels in the
east,at a distance of less than 100 miles in some cases, gas prices were as low as Henry Hub.
This resulted in extremely high wholesale power prices. The costs of producing electricity also exceeded
the wholesale generator offer cap which dangerously and inadvertently created incentives not to perform,
and thus, endangered grid reliability. Some generators were forced to run while losing money. Emergency
action by FERC is expected to alleviate this situation by providing “make-whole” payments to
generators.However, emergency action does not address the magnitude of the price premiums that are
resulting. To illustrate, were recent record prices in the Washington DC area to continue for just 7 days,
the annual cost ofwholesale power would approximately double. While a lesser result is more likely, there
arehuge potential implications for consumers and commercial entities, especially those not hedged and
caught unaware.
Careful policy and planning changes are needed to accommodate the new power gas relationship. For
example, PJM’s increased implementation of summer only procurement puts it in danger during strong
winter cold snaps of extremely high prices and reliability deficiencies. PJM needs to appropriately plan for
both peaks, summer and winter, as well as provide appropriate pricing signals to generators, perhaps by
tying generator offer caps to gas prices, rather than leaving them administratively set at $1000/MWh,
and find the right balance between automatic market mechanisms and administrative action.

PJM Natural Gas Prices Hit Record
Delivered natural gas prices in the downstream eastern gas markets (specifically, New England, the New
York City metro area, and portions of the Mid-Atlantic) reached an all-time record level, evensignificantly
surpassing levels reached just 2 weeks earlier, during the polar vortex. As shown by the figures below, gas
nd
prices reached $123/MMBtu on Wednesday January 22 , which is a premium of up to 2,520 percent over
Henry Hub, the traditional commodity market location in Louisiana.High prices due to natural gas delivery
2
shortages were predicted, though not the specific record levels.
1

http://www.icfi.com/insights/white-papers/2014/polar-vortex-energy-pricing-implications-commercial-opportunities-andsystem-reliability and http://www.icfi.com/insights/white-papers/2014/commercial-opportunities-and-system-reliability
2

http://www.isone.com/committees/comm_wkgrps/prtcpnts_comm/pac/mtrls/2013/dec182013/a3_icf_phase_2_gas_study_presentation. pdf

1

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© 2014 ICF International, Inc. All Rights Reserved.
Figure 1.Regional Gas Pricing – January 20, 21 and 22
140

©2014 ICF International, Inc.
All Rights Reserved.

120
Nominal $/MMBtu

Any views or opinions expressed in
this paper are solely those of the
author(s) and do not necessarily
represent those of ICF International.
This White Paper is provided for
informational purposes only and the
contents are subject to change
without notice. No contractual
obligations are formed directly or
indirectly by this document. ICF
MAKES NO WARRANTIES, EXPRESS,
IMPLIED, OR STATUTORY, AS TO THE
INFORMATION IN THIS DOCUMENT.

Monday Jan 20

100

Tuesday Jan 21

80

Wednesday Jan 22

60
40
20

No part of this document may be
reproduced or transmitted in any
form, or by any means (electronic,
mechanical, or otherwise), for any
purpose without prior written
permission.

0
Henry Dominion Chicago Algonquin Transco Z Transco Transco
Hub
South City Gate City Gate
5
Zone 6 NY Zone 6
Point
Non-NY

ICF and ICF INTERNATIONAL are
registered trademarks of ICF
International and/or its affiliates.
Other names may be trademarks of
their respective owners.

Source: SNL

In contrast, at locations just 100 miles or so upstream of the congested market areas, such as Dominion
South Point in Pennsylvania, gas prices were on par with Henry Hub.

About ICF International

Figure 2. Regional Gas Pricing Relative to Henry Hub

Since 1969, ICF International
(NASDAQ:ICFI) has been serving
government at all levels, major
corporations, and multilateral
institutions. With more than 60
offices and more than 4,500
employees worldwide, we bring deep
domain expertise, problem-solving
capabilities, and a results-driven
approach to deliver strategic value
across the lifecycle of client
programs.

Day

Henry Hub
($/MMbtu)

Dominion
South
Point

Chicago
City Gate

Monday Jan 20

4.55

-3%

13%

42%

9%

7%

8%

Tuesday Jan 21

4.39

3%

18%

321%

130%

211%

144%

Wednesday Jan 22

4.61

11%

46%

1120%

2508%

2519%

2579%

Algonquin
City Gate

Transco Z
5

Transco
Zone 6 NY

Transco
Zone 6
Non-NY

Source: SNL

At ICF, we partner with clients to
conceive and implement solutions
and services that protect and
improve the quality of life, providing
lasting answers to society’s most
challenging management,
technology, and policy issues. As a
company and individually, we live this
mission, as evidenced by our
commitment to sustainability and
carbon neutrality, contribution to the
global community, and dedication to
employee growth.

As can be seen in the figure below, the extreme price volatility seen in the eastern gas market was not
matched in western PJM. For the past three months, gas prices in Chicago and New Jersey were within
$1/MMBtu of each other. During the polar vortex earlier this month and the cold snap this week, that
th
rd
difference jumped, as Transco climbed to $40/MMBtu January 7 and $123/MMBtu January 23 .

A
l
A
l
l
R
i
g
h
t
s

2

R
e
s

icfi.com

© 2014 ICF International, Inc. All Rights Reserved.
Figure 3.Gas Pricing Comparison between Chicago and Transco Zone 6 (New Jersey)
140
Chicago
120

Nominal $/MMBTu

Transco Zone 6 Non-NY
100
80
60
40
20
0

Source: SNL

Consequences for Wholesale Power Prices
nd

As shown in the figure below, eastern PJM power exceeded the generator offer cap on January 22 . The
extremely high prices were also accompanied by the need to call operating reserves in some areas, notably
th
the areas around Washington, DC and Baltimore. This story is still developing; on Friday January 24 at
7:00 am, PEPCO real-time energy pricing hit $2,200/MWh and Dominion reached an even higher price,
$2,600/MWh. ICF is continuing to monitor this situation as it unfolds.
Also, the costs of producing incremental gas-fired power were so high as to be above the generator offer
cap. The highest price that a power plant can bid into the market in PJM (known as the generator offer cap)
is $1,000/MWh, even if their costs are higher. For example, natural gas prices hit $123/MMBtu on
Wednesday in New Jersey. The fuel portion of the operating cost of a marginal gas fired peaking
3
plant would be $2,706/MWh, but it could bid only $1,000. A 1000 MW plant would be losing $1,706,000
every hour or 287 million dollars per week. While this is only an illustrative situation designed to highlight
the potential consequences of not allowing generators to fully recover their fuel costs, it underlines the risk
to the system and generators created by the record high gas prices.
PJM made an announcement that because FERC was closed on Tuesday January 21 (due to the winter
weather), it was recommending that generators take the risk that ex post there would be alleviation of the
4
offer cap. In a document released on Tuesday, January 21, PJM stated:
PJM will file as soon as practical to seek a retroactive waiver of its system offer cap rule to “make whole”
generation resources to their documented costs to the extent such costs exceed the system offer cap. The waiver
would seek permission to reimburse affected generation resources through an “uplift” payment. While we

3Assumed 22,000 Btu/kWH heat rate, the heat rate used by ISO NE to calculate peakers margins; the heat rate is the rate of

converting fuel energy into electrical energy.
4http://www.pjm.com/~/media/documents/reports/20140121-cost-based-offers-into-the-day-ahead-energy-market-on-jan-21.ashx

3

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© 2014 ICF International, Inc. All Rights Reserved.
appreciate this predicament leaves some PJM generation capacity resources in an uncertain state, PJM has
consulted with counsel and believes the anticipated retroactive waiver request will likely be accepted by the FERC.

The dramatic announcement would not have been necessary if generator offer caps were a function of gas
prices times a conversion factor. Such a structure has been in place in other FERC regulated markets in the
past. The consequences of providing large economic incentives not to perform create unnecessary risks to
grid reliability. It should be noted that the highest administratively set price in the US is $5,000/MWh in
Texas, which is scheduled to increase to $9,000/MWh in 2015. Hence, Texas (actually the portion of Texas
regulated by the Public Utilities Commission of Texas) would not face such a problem even if gas prices
reached the recent record levels seen in the east (which they did not).
Figure 4.PJM Real-Time LMP Energy Pricing ($/MWh) – Wednesday January 22, 2014, 8:00 pm
ATSI: 170

COMED: 85

PENELEC: 264

JCPL: 458

PPL: 450
METED: 458

DUQ: 126

RECO: 417
PSEG: 448
PECO: 465

DAY: 113
AECO: 471

APS: 310

DEOK: 98

BGE: 1,804

DPL: 490

PEPCO: 1,847
EKPC: 120

AEP: 144

DOM: 654

Source: PJM

During this same period, as seen in the figure above, energy prices in western PJM were much lower,
reflecting extreme electric transmission congestion in bringing power east. Thus both the gas and power
transmission grids were short of transmission capacity and led to extreme price increases in the eastern
Mid-Atlantic. Thus, like the gas transportation bottlenecks that will be discussed below, wholesale price
disparity can point to potential new transmission line investments. One additional point to note is that
even though New Jersey had similar gas prices to the PEPCO area, its real-time energy pricing did not
exceed the offer cap. This is most likely due to a number of factors, some of which are fewer binding
transmission constraints.

Cause of High Downstream Natural Gas Prices
As shown in Figure 1 above, there was a wide spread between upstream (supply areas) and downstream
(market area) gas prices, indicating that constraints on pipeline capacity were the direct cause of the high
delivered gas prices. Gas utilities primarily serve residential and commercial (R/C) gas customers, and so
secure firm pipeline transportation contracts roughly equivalent to their customers’ projected winter peak
day loads to ensure reliability. In contrast, many gas-fired generators, mostly peaking units which only run
intermittently, rely on interruptible pipeline capacity.
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© 2014 ICF International, Inc. All Rights Reserved.
During summer peaks, when electricity demand is highest, residential and commercial (R/C) demand for
natural gas is low, and gas-fired generators usually encounter no problems securing interruptible pipeline
capacity. However, during winter cold snaps (such as those we have seen over the past several weeks),
the gas utilities need all their firm pipeline capacity to serve their R/C customers, leaving little (if any)
interruptible pipeline capacity available to peaking gas generators.
Over the past decade, most new power plants added in the US have been natural gas fired, and already
there has been significant retirement of non-gas fired units. As a result, natural gas has comprised an
increasingly larger proportion of the energy resource base. Recent and upcoming coal retirements will only
increase the need for natural gas for power generation, potentially exacerbating pricing during future
winter peaks.
High gas prices in constrained areas are price signals that developers may want to build new pipelines or
increase existing pipeline capacity. FERC is responsible for certifying and permitting new pipeline capacity.
In order to build a new pipeline or add capacity to an existing pipeline, pipeline companies must
demonstrate to FERC that the additional pipeline capacity is economically feasible by securing long-term
(generally 10-years or more) firm contracts for the added capacity. This is a high burden and increases the
costs and lead-time of new pipeline projects. This is especially difficultin most FERC-regulated ISO markets
because nearly all generation capacity is procured for one year only.

Increased Focus on Summer Only Resources
The cold weather highlights the need for careful policy and planning attention to reliability due to changes
in resource mix and market rules.The extremely high energy prices in PJM this winter are not only due to
5
the very cold weather, but also reflect decisions made by regulators. As stated in a previous white paper,
PJM has increasingly beenprocuring summer-only resources.
Interruptible load (demand response) accounts for half of PJM’s planning reserve margin, and around 80%
6
of that capacity is available only during the summer. Even in the summer, DR is not required to participate
in the energy market like generators, and hence is not available to ameliorate energy market price spikes.
The price of DR in the most recent capacity auction cleared at$59.37/MW-day, the same price as for
generation resources. The prices were the same even though generators can be called to operate during
the winter and are required to bid into the energy market, unlike most DR. DR lowers the clearing price of
capacity in the market, contributing to the retirement of generators. However these are precisely the
resources needed because they can be called in the winter and participate in the energy market. Finally,
DR does not have to provide attestation that it will be available when it is needed during the capacity
auction even though it is competing with existing generation resources subject to operational testing.FERC
proceedings are addressing this issue, but the outcome is uncertain.

Incentives for Reliable Winter Operation
In the absence of appropriate pricing signals during the winter, many choose to not adequately winterize
their facilities in order to be available during the coldest periods of the winter. Nearly 40 GW of capacity
was unavailable during the polar vortex, fully 20% of capacity in PJM.

5

http://www.icfi.com/insights/white-papers/2014/commercial-opportunities-and-system-reliability

6

PJM has three types of DR: Limited DR, which can only be dispatched in the summer; extended DR, which can be dispatched
from the spring to the fall; and annual DR, which can be called year-round. In the most recent RPM auction (2016/2017), of the nearly
10 GW of DR that cleared, 4.7 GW was limited DR, 3.4 GW was extended DR and only 1.8 GW was annual DR.

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© 2014 ICF International, Inc. All Rights Reserved.
Power plants which rely on natural gas are not required to have firm fuel delivery capability, which is
mostly required to operate during winter peak periods. Furthermore, administrativemechanisms which
estimate thecosts of gas fired powerplants and set their bid price into the energy market do not include
the costs of purchasing firm gas, which is typically estimated as a fixed cost. As a result, this and other
mechanisms fail to ensure adequate winter supply. Lastly, the hourly price caps set in markets,which can
have a large impact on resource availability, vary widely across markets and as discussed in the earlier ICF
white papers may need tobe increased. Lastly, estimates of the potential for winter outages turned out to
be too low, understating the need for winter supply.

Commercial Consequences
These price spikes represent a significant opportunity for some generators and a cautionary tale for
others. Coal units in eastern PJM, where this round of price spikes occurred, most likely earned a large
amount of revenue, as their fuel cost was small compared to the soaring gas price. Coal plants would earn
around $1,800 in revenue for every MWh they generated when prices were at shortage levels. If the cold
snap led to seven days of pricing at similar shortage levels, a typical sized coal plant (1,000 MW) would
earn over $302 million. To highlight the magnitude of such earnings, this level of margin roughly equals 30
percent of the capital investment cost of a new combined cycle power plant.
Another winning strategy isa combined cycle plant which has hedged its gas purchases. Combined cycles
of similar size to the coal plant above would have made similar profits.
Conversely, un-hedged entities face potentially catastrophic threats to corporate viability. In particular,
entities supplying power to retail load and financial hedging parties would be at significant risk. A similar
although less drastic cost is the missed opportunity for peakers. A 300 MW combustion turbine peaker
that could not dispatch due to winterization oversights missed roughly $91 million in revenues which
would be approximately forty percent the investment cost of a new gas peaker.

Conclusions
The system has successfully delivered power in spite of the cold weather, but it has “skated too close to
the edge,” resulting in unnecessarily record high prices and strains on the grid. While commercial
incentives may result in actions that help eliminate the problems associated with the changes in the gaspower relationship, a series of actions have contributed to exacerbating the problem. Thus, there is likely
to remain a combination of commercial opportunities and policy challenges. ICF expects to remain
involved in these areas.

Forquestions,pleasecontact:
JudahRose+1.703.934.3342judah.rose@icfi.com
Frank Brock+1.703.218.2741frank.brock@icfi.com

6

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© 2014 ICF International, Inc. All Rights Reserved.
AbouttheAuthors
Judah L. Rose joined ICF in 1982 and has over 30 years of experience in the energy industry. Mr. Rose’s
clients include electric utilities, financial institutions, law firms, government agencies, fuel companies,
and Independent Power Producers (IPP). Mr. Rose is one of ICF’s Distinguished Consultants, an
honorary title given to three of ICF’s 4,500 employees, and has served on the Board of Directors of ICF
International as the Management Shareholder Representative.Mr. Rose has supported the
development, acquisition, and financing of tens of billion dollars of new and existing power plants and
is a trusted counselor to the utility, IPP, andfinancial community. Mr. Rose frequently provides expert
testimony and litigation support. Mr. Rose has testified as an expert in scores of state and other legal
proceedings including in nearly 25 states, federal and international jurisdictions. Mr. Rose has also
addressed approximately 100 major energy conferences, authored numerous articles published in
Public Utilities Fortnightly, the Electricity Journal, Project Finance International, and written numerous
company studies. Mr. Rose received an M.P.P. from the John F. Kennedy School of Government,
Harvard University, and an S.B. in Economics from the Massachusetts Institute of Technology.
David Gerhardt, a principal with ICF, is an energy analyst with over 20 years of experience in energy
economics and energy engineering issues. Most of his work in energy economics has been in areas
such as asset valuation, wholesale power litigation, risk management, and PPA negotiations. Mr.
Gerhardt is the lead power generation engineer for ICF Consulting’s Wholesale Power group. As the
lead engineer, he reviews and develops all critical data required by the group, including new power
plant cost and performance characteristics by prime mover type, operation and maintenance
estimates, forced and scheduled outage rates, uprates, and emission rates. This work has included
developing cost estimates for dual fuel retrofits to CCGT machines.
Mr. Gerhardt is serving as lead consultant in a portfolio restructuring case and a wind developer
acquisition venture. Before joining ICF, he worked at Energy and Environmental Analysis, Inc., the New
York State Energy Office, and Solarex.
John Karp joined ICF International’s Wholesale Power team in 2007.With over 6 years of experience,
John has helped provide power market valuations, cash-flow forecasts and energy market forward
price curves for many different types of clients, such as independent power producers, investment
firms, utilities and state, federal and local governments and regulators.Mr. Karp has significant
experience using ICF’s proprietary energy model, IPM, to deliver long-term energy price forecasts and
power portfolio valuations.Mr. Karp received a BS and MS in Systems Engineering and Operations
Research from the George Washington University.
FrankBrockhas more than 17 years of experience in energy economics and modeling. His areas of
expertise include the analysis and modeling of natural gas end-use demand, natural gas use for
electric power generation, and renewable energy and energy efficiency technologies.At ICF
International, Mr. Brock has participated in dozens of studies for both public and private sector clients
on such topics such the valuation of energy infrastructure assets, the impacts of environmental
policies on energy markets, and long-term trends in energy demand.
Trisagni Sakya is a Research Assistant in ICF’s Energy Advisory Solutions practice for the Wholesale
Power Markets team. She has expertise in power price forecasting, plant valuations and power
market analysis. Trishagni uses ICF’s proprietary energy models, IPM and SRAM for detailed price
forecasts and analysis. Prior to working at ICF, Trishagni attended the Smith College and earned a B.A.
in Economics and Mathematics
Mohit Shresthajoined ICF International in 2011, and is an Analyst in ICF’s Energy Advisory Solutions
practice for the Wholesale Power Markets team. Mr. Shrestha has expertise in ICF's proprietary linear
program electricity model (IPM®), and has extensively used the model to provide decision analytics and
strategic support for new investments, merges and acquisitions, asset management, commercial
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© 2014 ICF International, Inc. All Rights Reserved.
contracting, financing due diligence,and integrated resource planning. He has gained extensive
experience in performing advanced quantitative and economic modeling, and analysis of energy
markets to assess and forecast the future of electric power and fuel prices market. Mr. Shrestha
earned a B.S. in Mathematical Economics and Applied Mathematics from Hampden-Sydney College.

8

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© 2014 ICF International, Inc. All Rights Reserved.

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Of Polar Vortexes and Price Spikes

  • 1. Of Polar Vortexes and PJM Price Spikes By Judah Rose, David Gerhardt, John Karp,Frank Brock,Trisagni Sakya and Mohit Shrestha ICF International Executive Summary 1 As discussed in the previous Polar Vortex white papers, extremely high power prices create significant commercial opportunities that can be partly predicted in advance and also highlight the need for careful attention to reliability policy and planning due to changes in resource mix and market rules. These conclusions have been dramatically reinforced by the developments of the past few days – January 20-24, 2014. Delivered natural gas prices in the east reached all-time record levels of well above $100/MMBtu, and also well above prices in early January 2014 – one key delivered gas price was 3 times higher, $123/MMBtu versus $40/MMBtu. Meanwhile the gas price at Henry Hub, the traditional benchmark for natural gas prices, was less than $5/MMBtu. Indeed, while some gas prices were at record levels in the east,at a distance of less than 100 miles in some cases, gas prices were as low as Henry Hub. This resulted in extremely high wholesale power prices. The costs of producing electricity also exceeded the wholesale generator offer cap which dangerously and inadvertently created incentives not to perform, and thus, endangered grid reliability. Some generators were forced to run while losing money. Emergency action by FERC is expected to alleviate this situation by providing “make-whole” payments to generators.However, emergency action does not address the magnitude of the price premiums that are resulting. To illustrate, were recent record prices in the Washington DC area to continue for just 7 days, the annual cost ofwholesale power would approximately double. While a lesser result is more likely, there arehuge potential implications for consumers and commercial entities, especially those not hedged and caught unaware. Careful policy and planning changes are needed to accommodate the new power gas relationship. For example, PJM’s increased implementation of summer only procurement puts it in danger during strong winter cold snaps of extremely high prices and reliability deficiencies. PJM needs to appropriately plan for both peaks, summer and winter, as well as provide appropriate pricing signals to generators, perhaps by tying generator offer caps to gas prices, rather than leaving them administratively set at $1000/MWh, and find the right balance between automatic market mechanisms and administrative action. PJM Natural Gas Prices Hit Record Delivered natural gas prices in the downstream eastern gas markets (specifically, New England, the New York City metro area, and portions of the Mid-Atlantic) reached an all-time record level, evensignificantly surpassing levels reached just 2 weeks earlier, during the polar vortex. As shown by the figures below, gas nd prices reached $123/MMBtu on Wednesday January 22 , which is a premium of up to 2,520 percent over Henry Hub, the traditional commodity market location in Louisiana.High prices due to natural gas delivery 2 shortages were predicted, though not the specific record levels. 1 http://www.icfi.com/insights/white-papers/2014/polar-vortex-energy-pricing-implications-commercial-opportunities-andsystem-reliability and http://www.icfi.com/insights/white-papers/2014/commercial-opportunities-and-system-reliability 2 http://www.isone.com/committees/comm_wkgrps/prtcpnts_comm/pac/mtrls/2013/dec182013/a3_icf_phase_2_gas_study_presentation. pdf 1 icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 2. Figure 1.Regional Gas Pricing – January 20, 21 and 22 140 ©2014 ICF International, Inc. All Rights Reserved. 120 Nominal $/MMBtu Any views or opinions expressed in this paper are solely those of the author(s) and do not necessarily represent those of ICF International. This White Paper is provided for informational purposes only and the contents are subject to change without notice. No contractual obligations are formed directly or indirectly by this document. ICF MAKES NO WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, AS TO THE INFORMATION IN THIS DOCUMENT. Monday Jan 20 100 Tuesday Jan 21 80 Wednesday Jan 22 60 40 20 No part of this document may be reproduced or transmitted in any form, or by any means (electronic, mechanical, or otherwise), for any purpose without prior written permission. 0 Henry Dominion Chicago Algonquin Transco Z Transco Transco Hub South City Gate City Gate 5 Zone 6 NY Zone 6 Point Non-NY ICF and ICF INTERNATIONAL are registered trademarks of ICF International and/or its affiliates. Other names may be trademarks of their respective owners. Source: SNL In contrast, at locations just 100 miles or so upstream of the congested market areas, such as Dominion South Point in Pennsylvania, gas prices were on par with Henry Hub. About ICF International Figure 2. Regional Gas Pricing Relative to Henry Hub Since 1969, ICF International (NASDAQ:ICFI) has been serving government at all levels, major corporations, and multilateral institutions. With more than 60 offices and more than 4,500 employees worldwide, we bring deep domain expertise, problem-solving capabilities, and a results-driven approach to deliver strategic value across the lifecycle of client programs. Day Henry Hub ($/MMbtu) Dominion South Point Chicago City Gate Monday Jan 20 4.55 -3% 13% 42% 9% 7% 8% Tuesday Jan 21 4.39 3% 18% 321% 130% 211% 144% Wednesday Jan 22 4.61 11% 46% 1120% 2508% 2519% 2579% Algonquin City Gate Transco Z 5 Transco Zone 6 NY Transco Zone 6 Non-NY Source: SNL At ICF, we partner with clients to conceive and implement solutions and services that protect and improve the quality of life, providing lasting answers to society’s most challenging management, technology, and policy issues. As a company and individually, we live this mission, as evidenced by our commitment to sustainability and carbon neutrality, contribution to the global community, and dedication to employee growth. As can be seen in the figure below, the extreme price volatility seen in the eastern gas market was not matched in western PJM. For the past three months, gas prices in Chicago and New Jersey were within $1/MMBtu of each other. During the polar vortex earlier this month and the cold snap this week, that th rd difference jumped, as Transco climbed to $40/MMBtu January 7 and $123/MMBtu January 23 . A l A l l R i g h t s 2 R e s icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 3. Figure 3.Gas Pricing Comparison between Chicago and Transco Zone 6 (New Jersey) 140 Chicago 120 Nominal $/MMBTu Transco Zone 6 Non-NY 100 80 60 40 20 0 Source: SNL Consequences for Wholesale Power Prices nd As shown in the figure below, eastern PJM power exceeded the generator offer cap on January 22 . The extremely high prices were also accompanied by the need to call operating reserves in some areas, notably th the areas around Washington, DC and Baltimore. This story is still developing; on Friday January 24 at 7:00 am, PEPCO real-time energy pricing hit $2,200/MWh and Dominion reached an even higher price, $2,600/MWh. ICF is continuing to monitor this situation as it unfolds. Also, the costs of producing incremental gas-fired power were so high as to be above the generator offer cap. The highest price that a power plant can bid into the market in PJM (known as the generator offer cap) is $1,000/MWh, even if their costs are higher. For example, natural gas prices hit $123/MMBtu on Wednesday in New Jersey. The fuel portion of the operating cost of a marginal gas fired peaking 3 plant would be $2,706/MWh, but it could bid only $1,000. A 1000 MW plant would be losing $1,706,000 every hour or 287 million dollars per week. While this is only an illustrative situation designed to highlight the potential consequences of not allowing generators to fully recover their fuel costs, it underlines the risk to the system and generators created by the record high gas prices. PJM made an announcement that because FERC was closed on Tuesday January 21 (due to the winter weather), it was recommending that generators take the risk that ex post there would be alleviation of the 4 offer cap. In a document released on Tuesday, January 21, PJM stated: PJM will file as soon as practical to seek a retroactive waiver of its system offer cap rule to “make whole” generation resources to their documented costs to the extent such costs exceed the system offer cap. The waiver would seek permission to reimburse affected generation resources through an “uplift” payment. While we 3Assumed 22,000 Btu/kWH heat rate, the heat rate used by ISO NE to calculate peakers margins; the heat rate is the rate of converting fuel energy into electrical energy. 4http://www.pjm.com/~/media/documents/reports/20140121-cost-based-offers-into-the-day-ahead-energy-market-on-jan-21.ashx 3 icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 4. appreciate this predicament leaves some PJM generation capacity resources in an uncertain state, PJM has consulted with counsel and believes the anticipated retroactive waiver request will likely be accepted by the FERC. The dramatic announcement would not have been necessary if generator offer caps were a function of gas prices times a conversion factor. Such a structure has been in place in other FERC regulated markets in the past. The consequences of providing large economic incentives not to perform create unnecessary risks to grid reliability. It should be noted that the highest administratively set price in the US is $5,000/MWh in Texas, which is scheduled to increase to $9,000/MWh in 2015. Hence, Texas (actually the portion of Texas regulated by the Public Utilities Commission of Texas) would not face such a problem even if gas prices reached the recent record levels seen in the east (which they did not). Figure 4.PJM Real-Time LMP Energy Pricing ($/MWh) – Wednesday January 22, 2014, 8:00 pm ATSI: 170 COMED: 85 PENELEC: 264 JCPL: 458 PPL: 450 METED: 458 DUQ: 126 RECO: 417 PSEG: 448 PECO: 465 DAY: 113 AECO: 471 APS: 310 DEOK: 98 BGE: 1,804 DPL: 490 PEPCO: 1,847 EKPC: 120 AEP: 144 DOM: 654 Source: PJM During this same period, as seen in the figure above, energy prices in western PJM were much lower, reflecting extreme electric transmission congestion in bringing power east. Thus both the gas and power transmission grids were short of transmission capacity and led to extreme price increases in the eastern Mid-Atlantic. Thus, like the gas transportation bottlenecks that will be discussed below, wholesale price disparity can point to potential new transmission line investments. One additional point to note is that even though New Jersey had similar gas prices to the PEPCO area, its real-time energy pricing did not exceed the offer cap. This is most likely due to a number of factors, some of which are fewer binding transmission constraints. Cause of High Downstream Natural Gas Prices As shown in Figure 1 above, there was a wide spread between upstream (supply areas) and downstream (market area) gas prices, indicating that constraints on pipeline capacity were the direct cause of the high delivered gas prices. Gas utilities primarily serve residential and commercial (R/C) gas customers, and so secure firm pipeline transportation contracts roughly equivalent to their customers’ projected winter peak day loads to ensure reliability. In contrast, many gas-fired generators, mostly peaking units which only run intermittently, rely on interruptible pipeline capacity. 4 icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 5. During summer peaks, when electricity demand is highest, residential and commercial (R/C) demand for natural gas is low, and gas-fired generators usually encounter no problems securing interruptible pipeline capacity. However, during winter cold snaps (such as those we have seen over the past several weeks), the gas utilities need all their firm pipeline capacity to serve their R/C customers, leaving little (if any) interruptible pipeline capacity available to peaking gas generators. Over the past decade, most new power plants added in the US have been natural gas fired, and already there has been significant retirement of non-gas fired units. As a result, natural gas has comprised an increasingly larger proportion of the energy resource base. Recent and upcoming coal retirements will only increase the need for natural gas for power generation, potentially exacerbating pricing during future winter peaks. High gas prices in constrained areas are price signals that developers may want to build new pipelines or increase existing pipeline capacity. FERC is responsible for certifying and permitting new pipeline capacity. In order to build a new pipeline or add capacity to an existing pipeline, pipeline companies must demonstrate to FERC that the additional pipeline capacity is economically feasible by securing long-term (generally 10-years or more) firm contracts for the added capacity. This is a high burden and increases the costs and lead-time of new pipeline projects. This is especially difficultin most FERC-regulated ISO markets because nearly all generation capacity is procured for one year only. Increased Focus on Summer Only Resources The cold weather highlights the need for careful policy and planning attention to reliability due to changes in resource mix and market rules.The extremely high energy prices in PJM this winter are not only due to 5 the very cold weather, but also reflect decisions made by regulators. As stated in a previous white paper, PJM has increasingly beenprocuring summer-only resources. Interruptible load (demand response) accounts for half of PJM’s planning reserve margin, and around 80% 6 of that capacity is available only during the summer. Even in the summer, DR is not required to participate in the energy market like generators, and hence is not available to ameliorate energy market price spikes. The price of DR in the most recent capacity auction cleared at$59.37/MW-day, the same price as for generation resources. The prices were the same even though generators can be called to operate during the winter and are required to bid into the energy market, unlike most DR. DR lowers the clearing price of capacity in the market, contributing to the retirement of generators. However these are precisely the resources needed because they can be called in the winter and participate in the energy market. Finally, DR does not have to provide attestation that it will be available when it is needed during the capacity auction even though it is competing with existing generation resources subject to operational testing.FERC proceedings are addressing this issue, but the outcome is uncertain. Incentives for Reliable Winter Operation In the absence of appropriate pricing signals during the winter, many choose to not adequately winterize their facilities in order to be available during the coldest periods of the winter. Nearly 40 GW of capacity was unavailable during the polar vortex, fully 20% of capacity in PJM. 5 http://www.icfi.com/insights/white-papers/2014/commercial-opportunities-and-system-reliability 6 PJM has three types of DR: Limited DR, which can only be dispatched in the summer; extended DR, which can be dispatched from the spring to the fall; and annual DR, which can be called year-round. In the most recent RPM auction (2016/2017), of the nearly 10 GW of DR that cleared, 4.7 GW was limited DR, 3.4 GW was extended DR and only 1.8 GW was annual DR. 5 icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 6. Power plants which rely on natural gas are not required to have firm fuel delivery capability, which is mostly required to operate during winter peak periods. Furthermore, administrativemechanisms which estimate thecosts of gas fired powerplants and set their bid price into the energy market do not include the costs of purchasing firm gas, which is typically estimated as a fixed cost. As a result, this and other mechanisms fail to ensure adequate winter supply. Lastly, the hourly price caps set in markets,which can have a large impact on resource availability, vary widely across markets and as discussed in the earlier ICF white papers may need tobe increased. Lastly, estimates of the potential for winter outages turned out to be too low, understating the need for winter supply. Commercial Consequences These price spikes represent a significant opportunity for some generators and a cautionary tale for others. Coal units in eastern PJM, where this round of price spikes occurred, most likely earned a large amount of revenue, as their fuel cost was small compared to the soaring gas price. Coal plants would earn around $1,800 in revenue for every MWh they generated when prices were at shortage levels. If the cold snap led to seven days of pricing at similar shortage levels, a typical sized coal plant (1,000 MW) would earn over $302 million. To highlight the magnitude of such earnings, this level of margin roughly equals 30 percent of the capital investment cost of a new combined cycle power plant. Another winning strategy isa combined cycle plant which has hedged its gas purchases. Combined cycles of similar size to the coal plant above would have made similar profits. Conversely, un-hedged entities face potentially catastrophic threats to corporate viability. In particular, entities supplying power to retail load and financial hedging parties would be at significant risk. A similar although less drastic cost is the missed opportunity for peakers. A 300 MW combustion turbine peaker that could not dispatch due to winterization oversights missed roughly $91 million in revenues which would be approximately forty percent the investment cost of a new gas peaker. Conclusions The system has successfully delivered power in spite of the cold weather, but it has “skated too close to the edge,” resulting in unnecessarily record high prices and strains on the grid. While commercial incentives may result in actions that help eliminate the problems associated with the changes in the gaspower relationship, a series of actions have contributed to exacerbating the problem. Thus, there is likely to remain a combination of commercial opportunities and policy challenges. ICF expects to remain involved in these areas. Forquestions,pleasecontact: JudahRose+1.703.934.3342judah.rose@icfi.com Frank Brock+1.703.218.2741frank.brock@icfi.com 6 icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 7. AbouttheAuthors Judah L. Rose joined ICF in 1982 and has over 30 years of experience in the energy industry. Mr. Rose’s clients include electric utilities, financial institutions, law firms, government agencies, fuel companies, and Independent Power Producers (IPP). Mr. Rose is one of ICF’s Distinguished Consultants, an honorary title given to three of ICF’s 4,500 employees, and has served on the Board of Directors of ICF International as the Management Shareholder Representative.Mr. Rose has supported the development, acquisition, and financing of tens of billion dollars of new and existing power plants and is a trusted counselor to the utility, IPP, andfinancial community. Mr. Rose frequently provides expert testimony and litigation support. Mr. Rose has testified as an expert in scores of state and other legal proceedings including in nearly 25 states, federal and international jurisdictions. Mr. Rose has also addressed approximately 100 major energy conferences, authored numerous articles published in Public Utilities Fortnightly, the Electricity Journal, Project Finance International, and written numerous company studies. Mr. Rose received an M.P.P. from the John F. Kennedy School of Government, Harvard University, and an S.B. in Economics from the Massachusetts Institute of Technology. David Gerhardt, a principal with ICF, is an energy analyst with over 20 years of experience in energy economics and energy engineering issues. Most of his work in energy economics has been in areas such as asset valuation, wholesale power litigation, risk management, and PPA negotiations. Mr. Gerhardt is the lead power generation engineer for ICF Consulting’s Wholesale Power group. As the lead engineer, he reviews and develops all critical data required by the group, including new power plant cost and performance characteristics by prime mover type, operation and maintenance estimates, forced and scheduled outage rates, uprates, and emission rates. This work has included developing cost estimates for dual fuel retrofits to CCGT machines. Mr. Gerhardt is serving as lead consultant in a portfolio restructuring case and a wind developer acquisition venture. Before joining ICF, he worked at Energy and Environmental Analysis, Inc., the New York State Energy Office, and Solarex. John Karp joined ICF International’s Wholesale Power team in 2007.With over 6 years of experience, John has helped provide power market valuations, cash-flow forecasts and energy market forward price curves for many different types of clients, such as independent power producers, investment firms, utilities and state, federal and local governments and regulators.Mr. Karp has significant experience using ICF’s proprietary energy model, IPM, to deliver long-term energy price forecasts and power portfolio valuations.Mr. Karp received a BS and MS in Systems Engineering and Operations Research from the George Washington University. FrankBrockhas more than 17 years of experience in energy economics and modeling. His areas of expertise include the analysis and modeling of natural gas end-use demand, natural gas use for electric power generation, and renewable energy and energy efficiency technologies.At ICF International, Mr. Brock has participated in dozens of studies for both public and private sector clients on such topics such the valuation of energy infrastructure assets, the impacts of environmental policies on energy markets, and long-term trends in energy demand. Trisagni Sakya is a Research Assistant in ICF’s Energy Advisory Solutions practice for the Wholesale Power Markets team. She has expertise in power price forecasting, plant valuations and power market analysis. Trishagni uses ICF’s proprietary energy models, IPM and SRAM for detailed price forecasts and analysis. Prior to working at ICF, Trishagni attended the Smith College and earned a B.A. in Economics and Mathematics Mohit Shresthajoined ICF International in 2011, and is an Analyst in ICF’s Energy Advisory Solutions practice for the Wholesale Power Markets team. Mr. Shrestha has expertise in ICF's proprietary linear program electricity model (IPM®), and has extensively used the model to provide decision analytics and strategic support for new investments, merges and acquisitions, asset management, commercial 7 icfi.com © 2014 ICF International, Inc. All Rights Reserved.
  • 8. contracting, financing due diligence,and integrated resource planning. He has gained extensive experience in performing advanced quantitative and economic modeling, and analysis of energy markets to assess and forecast the future of electric power and fuel prices market. Mr. Shrestha earned a B.S. in Mathematical Economics and Applied Mathematics from Hampden-Sydney College. 8 icfi.com © 2014 ICF International, Inc. All Rights Reserved.