PAC: BPM020 and 015 Edits for SATOA (PAC004) (20210811)

The Environmental Sector appreciates the opportunity to provide feedback to MISO on the SATOA BPM 15 and BPM 20 changes.  We strongly support MISO’s effort to bring more clarity to BPM 15 by specifically listing SATOAs in Section 6.1.1.1.1 as a potential means of mitigating constraints.  We also appreciate MISO’s clarification in (proposed) Section A.2 of BPM 20 that SATOAs approved in a previous MTEP cycle are available for evaluation to mitigate constraints in future DPP studies -  “Further, a SATOA approved in a prior MTEP cycle as one transmission project type, could be considered to resolve the newly identified Transmission Issues of any transmission project type.” - with GIP driven upgrades recognized as a “transmission type” in Section 2.3 of BPM 20. 

The Environmental Sector strongly encourages MISO to ensure that SATOAs are only approved in MTEP cycles when they meet demonstrated reliability needs. We are concerned that the “other” category offers an opportunity for transmission owners to submit projects that receive very little scrutiny from MISO. We request that MISO add language in BPM 20 Section A3 (or elsewhere, if more appropriate) indicating that MISO will only review and approve proposed SATOAs based on the SATOA’s ability to meet a demonstrated reliability need. 

Local Planning Criteria is proposed to be used by MISO in determining if detailed EMTP will be required. We support this but believe MISO must make it clear that Local Planning Criteria will be used in the evaluation of potential negative impacts to the MISO transmission system, and impacts to other generators in the “harm test” that is used to evaluate additional costs that must be considered in the economic evaluation of SATOAs.  

We appreciate MISO’s willingness to inform generators in the interconnection process about proposed and retiring SATOAs in the current MTEP cycle. We do not believe that simply presenting this information in the Subregional Planning meetings is sufficient. This has been MISO’s method of communicating with generators to date in regard to proposed SATOAs, and has been seriously lacking in meeting the objective of informing impacted interconnection customers. We strongly recommend that MISO provide this information in ways that will actually reach generators, such as in a presentation at the Interconnection Process Working Group, in a list/link on the GIP website, and/or directly reaching out to generators in the interconnection queue electrically near proposed additions or removals of SATOAs. 

Finally, we would like to again request that the operating guides for SATOAs be made available to entities with CEII and UNDA approval. We understand that MISO has stated that in the MTEP subregional planning meetings the operating information used to create the Operating Guide will be presented to stakeholders, but we believe that further and complete details that will be included in the operating guide must be made available to stakeholders who have CEII and UNDA certification. 

We appreciate MISO’s consideration of these requests. 

Respectfully submitted, 
MISO Environmental Sector

Savion, LLC (“Savion”) would like to thank MISO for bringing this item to stakeholders for discussion. In the August 11, 2021 meeting of the Planning Advisory Committee (PAC), MISO presented proposed edits to BPM 020 Transmission Planning and BPM 015 Generator Interconnection for Storage as a Transmission Only Asset (PAC004).

Savion is generally supportive of the proposed BPM modifications proposed.  We hold that MISO continue to keep SATOA within the confines of transmission planning.  SATOA should not have access to market revenue.  If a TO wants to earn market revenue for energy storage, the SATOA should be required to follow the GI process like all other generation.

At the August 11, 2021 meeting of the Planning Advisory Committee (PAC), MISO presented proposed edits to BPM 020 Transmission Planning and BPM 015 Generator Interconnection for Storage as a Transmission Only Asset (PAC004), along with a SATOA Life Cycle Cost Estimates Workbook and a SATOA Eligibility Checklist.  The MISO Transmission Owners provide the following feedback on the Life Cycle Cost Estimates Workbook.

 Definitions – The spreadsheet requests the following items without providing a definition and calculation for each input (these are assumptions to be input toward the top of the spreadsheets):

1. Discount Rate – The BPM does not identify the proper discount rate to use for this analysis.  In Attachment FF the discount rate is identified as the after-tax weighted average cost of capital of the Transmission owners of the system. The “system” needs to clarified for the analysis, is it the portion of MISO that the costs will be recovered over either the pricing zone or all of MISO or some other subsection? 
2. Rate Base Factor – This input is not defined in any of the documents and is key to calculating the ATRR. Is this a factor that should include return and income taxes?
3. Expense Factor - This input is not defined in any of the documents. The annual O&M will likely not be a fixed percentage of Gross Plant; it will likely escalate with inflation or some other basis if not vary each year.

 Deferred Taxes – The model does not factor the deferred income taxes into the calculation of the ATRR and should be included in the MISO Model.

 Proposed Section A.5 Retirement of SATOA

No SATOA may be retired from service permanently unless the retirement is submitted into the annual MTEP planning process as a proposed project retirement, reviewed by MISO for its impact on Transmission System performance, and accepted by MISO based on such review. Generation Facilities in the Definitive Planning Phases in proximity to the SATOA will be notified from MISO at the applicable Subregional Planning Meeting when an assessment of a SATOA retirement occurs. Any SATOA facility retiring as a transmission asset that desires to operate as a resource must also obtain a Generator Interconnection Agreement to operate and follow the MISO Generator Interconnection Procedures.

 The Owners are concerned that the proposed Section A.5 go beyond the provisions of Attachment FF and recommend deleting the last two sentences of this section.

• Regarding retirement in a manner that these transmission solutions differently than other transmission solutions, relative to their retirements and creates ambiguity in the process of retiring a SATOA.  The Owners recommend deleting the last two sentences of this section.
• Regarding Market Participation of a retiring SATOA, Market Participation requirements are being developed through the MSC now and this has not been determined to be a requirement, so it is likely more appropriate to say that the SATOA must follow the rules established for Market Participation; also this statement is not related to the retirement of a SATOA, but rather the conditions under which it might perform another service, and should likely be deleted all together

For reference, retirement – related language in Attachment FF:

7. Removal No SATOA may be removed from service permanently unless the removal is submitted into the annual MTEP planning process as a proposed project removal, reviewed by the Transmission Provider for its impact on Transmission System performance, and accepted by the Transmission Provider based on such review.