MSC: Hybrid Resource Participation - Market Participant Presentation (20210311)

Savion agrees with the comments provided by Rhonda Peters with Clean Grid Alliance.

Of chief concern, hybrid technology may provide improved reliability from the diversity of fuel and alternative modes of operation that may not be captured in the simple additive method proposed.  If MISO prevails and delay 841 implementation a further three years, hybrid developers may be harmed if diversity of operation is not quantified.

Clean Grid Alliance Comments on Hybrid Market Participation

March 25, 2021

Clean Grid Alliance appreciates the opportunity to provide comments on the Hybrid Markets Participation stakeholder-led discussion at the March MSC. MISO had presented on this topic in August and Sept of 2020 and had planned to follow up in Q1 2021, but Q1 is now passed with no specific date set on the MSC management plan. We encourage MISO to follow up and present on this topic as soon as possible, including specific responses to the stakeholder-led presentation. 

Also, we appreciate MISO’s receptiveness to putting together a Gantt Chart or something similar to lay out the schedule of activities needed to implement Order 841 Compliance as well as implementation of the MSE project. Having regular updates will be greatly appreciated by MISO stakeholders. 

As discussed at the last MSC, MISO recently filed for an additional 3 year extension to its implementation Order 841 Compliance, for a total of 7 years of delays to implementation. Currently, over 7500 MW of battery storage and hybrid projects (see attached spreadsheets) are in the MISO interconnection queue, having put over $29,000,000 in “milestone deposits” for those requests, with about half of the $29M already “at risk” should the projects not proceed or reach COD within 3 years of the date provided on their application. Over 4000MW of the 7500MW are actually hybrid projects that contain energy storage as one hybrid component. Additionally, the “0MW” interconnections on the stand alone battery storage list are “Surplus” additions to existing projects that can make those projects hybrid as well. Hybrid projects could potentially reach COD and participate in the MISO market, regardless of the implementation of Order 841, should changes be made to various market models to accommodate hybrids, as presented by MISO stakeholders at the March MSC (https://cdn.misoenergy.org/20210311%20MSC%20Item%2009%20Hybrid%20Resource%20Presentation_GPI529699.pdf). Therefore, the exploration and potential implementation of the short-term options put forward by the stakeholder coalition, especially those that could be implemented with minimal software adjustments, are even more critical, given the potential for Order 841 delays. The questions we have for MISO on this are whether the stakeholder suggested market changes to accommodate hybrid projects are considered “feasible” by MISO (and why or why not) and if feasible, what steps are needed for implementation, and in what timeframe can they be achieved? 

Clean Grid Alliance again thanks MISO for the great start last year on hybrid market participation and encourages MISO to set a firm date and schedule to complete that work as soon as possible. 

Sincerely

Rhonda Peters, Ph.D., consultant

Natalie McIntire, consultant

Clean Grid Alliance

Attached: 

-Spreadsheet of stand-alone energy storage projects in the MISO interconnection queue, as of March 16^th, 2021, planned for COD prior to June 2025

-Spreadsheet of hybrid interconnection projects that include energy storage in the MISO interconnection queue, as of March 16^th, 2021, planned for COD prior to June 2025