In the September 22 meeting of the Planning Advisory Committee (PAC), MISO presented draft updates to BPM-020 and 015 revisions for Storage as a Transmission Only Asset (SATOA) for stakeholder feedback. Also provided for feedback was a SATOA eligibility checklist and SATOA life-cycle cost estimate spreadsheet.
Comments are due by October 1.
The MISO Transmission Owners appreciate the opportunity to provide feedback on the topic of BPM-020 and BPM 015 revisions for Storage as a Transmission Only Asset (SATOA).
The Owners appreciate MISO including the definitions for Discount Factor, Rate Base Factor, and Expense Factor in the SATOA life-cycle cost estimate spreadsheet. However, we also request that MISO include the actual formula for Rate Base Factor and Expense Factor, or alternatively identify where in the Tariff these values are located so that we ensure a standard formula is used.
Regarding proposed Section A.5 (Retirement of SATOA), additional clarity is needed about how to submit a proposed SATOA’s retirement into the annual MTEP planning process as a “proposed project retirement.” The MTEP database doesn’t have a standard mechanism to reflect a project retirement so MISO should give additional direction on the proposed retirement submission process.
Finally, regarding proposed Section A.5.1 (Retired SATOA), the Owners propose striking the following language below:
Any SATOA facility that has retired as a transmission asset and desires to operate as a resource must also obtain a Generator Interconnection Agreement to operate and follow the MISO Generator Interconnection Procedures and any market participation requirements.
While a Generator Interconnection Agreement may ultimately be needed if a SATOA decides to operate as a resource, the conversations in the Market Subcommittee have not yet come to a conclusion on this topic. The proposed language should not presuppose a course of action on this conversion process. We also believe should a Generator Interconnection Agreement be necessary, the remaining reference to following the MISO Generator Interconnection Procedures and market participation requirements would provide adequate direction once these processes are determined.
MISO's proposed revisions to BPM-020 for SATOA retirement lack specific procedures for the reliability evaluation triggered by a SATOA retirement request. BPM-020 Section 6.2.5 already includes procedures for the reliability evaluation of Attachment Y generation retirement requests. MISO could apply similar procedures for SATOA retirement requests and define the procedures in BPM-020 or MISO could refer in the SATOA retirement request section to Section 6.2.5. Not addressing the specific procedures for the reliability evaluation triggered by SATOA retirement will create an inconsistency with other types of facility retirements.