PSC: Address Congestion at Existing Resources in Planning (PAC-2021-1) (20210427)

Clean Grid Alliance Comments on Congestion at Existing Resources in Planning

MISO Planning Subcommittee

May 13, 2021

Clean Grid Alliance appreciates the opportunity to provide comments on the Planning Subcommittee topic of Congestion at Existing Resources in Planning. The first thing we would like to point out is that this issue is not a reliability issue related to Generator Interconnection. It’s a market issue related to congestion. In a competitive market environment, there will be more generators available than load. This leads to congestion, which is a natural byproduct of market environment. 

In listening to the stakeholder discussions on this topic, it seems clear the issues can be broken down into 2 categories –short term due to Generator Interconnection Network Upgrades not being constructed, and long term congestion related to the nature of a market environment. Again, neither of these issues relate to reliability. 

The short term issues relate to “fairness” in dispatch and are currently addressed through the Annual ERIS, NRIS and QOL processes. 

The long term issues relate to market congestion and this is where MISO’s historic deficiency in Market Efficiency Projects (MEPs) creates harm. MEP projects’ threshold criteria are so high it is difficult to get any approved through the annual MTEP planning process. In fact, we are aware of generators that have paid for Network Upgrades via participant funding for the purpose of addressing congestion after all requirements for reliability were met, and the project was operating. 

We strongly encourage MISO to lower the bar for approval of MEP projects, as we believe this is the appropriate mechanism to address congestion at existing generators. Some suggestions for addressing this are (1) reducing the required B/C ratio from 1.25 to 1.0 and (2) evaluating the benefits of transmission projects on a 40 year basis rather than 20 years as 40 years is much more reflective of the actual life expectancy of transmission upgrades.

Sincerely, 

Rhonda Peters, Ph.D.

Technical Consultant for Clean Grid Alliance

Transmission Owner Sector Feedback on Congestion at Existing Resources

May 13, 2021

During the April 27, 2021 Planning Subcommittee (PSC) meeting, MISO framed the discussion regarding Congestion at Existing Resources in Planning (PAC-2021-1.  Several questions were presented for stakeholders to consider and respond to.  The Transmission Owners address some of these questions in the comments below, but there is not sufficient time provided for feedback submission for the Owners to develop a more complete response so, the Owners note generally that this is a topic of interest to  the Owners, on which Sector feedback has submitted in the past.

In response to some of the questions MISO posed for Stakeholder feedback:

• What "existing" generation resources should be considered (e.g. NRIS, ERIS, Conditional, Unconditional) in this discussion?

NRIS, Unconditional units should be considered in this effort, as output from NRIS is intended to be “deliverable” to the MISO system, while ERIS has only non-firm injection rights.

• What real time congestion should be considered a reliability problem that needs addressed in reliability planning processes?

Congestion is an economic issue, not a reliability issue.

• What specific planning process, if any, should be reviewed?

This issue reflects concerns raised by the Owners most recently in CPP discussions at the PSC last year, relating to several DPP studies assumptions that contribute to congestion on the transmission system; some of these, which the Owners see as the most significant drivers of congestion at existing resources, are described in the comments below.

• The availability of an ERIS product contributes to real time congestion because transmission system upgrades necessary for deliverability to load are assigned to NRIS units only (and maintained by the load thereafter), while ERIS and NRIS units are not differentiated in Market dispatch.
• Market dispatch is not consistent with the dispatch of generating units in transmission planning studies (e.g. Annual deliverability, reliability, or economic).  Outage assumptions in real time Operation Planning also lead to congestion (planning assumes N-1, but operating assumes N-1-1 conditions).  Planning models start with system in-tact and then perform contingency analysis by taking elements out, where-as operations is never “system in tact” and outages are assumed from the current state; thus missing upgrades in Interconnection studies results in real-time congestion.
• When MISO began dispatching existing resources based on their fuel-type in DPP studies, the intent was to model these resources as they would operate, relative to the other generation in the area.  However if the output being studied cannot accommodated by the resulting dispatch, existing generation in the study area is further backed down pro-rata; this is not logically consistent with how these resources would operate in real time, so turning down the same resource type in interconnection study models also contributes to real-time system congestion.
• As noted by MISO in the context of the Coordinated Planning Process discussions at the PSC in 2020, dFax assumptions and the limited range of system conditions studied in the DPP process  also contribute to congestion on the system, often leading to “economic curtailments”.

As the generation fleet transitions to more intermittent resources, more MW of generating capacity needs to be added to achieve the same level of capacity credits.  MISO’s recent reduction of solar dispatch to zero in the DPP shoulder study case[1] (one of only two DPP study cases) at the same time as solar has become the predominate resource-type in the queue is likely to exacerbate these issues, already seen with recent wind development in MISO.

The Environmental Sector appreciates this opportunity to provide comments to the PSC on the topic of “Congestion at Existing Resources in Planning”. Our main concern about this issue is that congestion is an economic issue and not a reliability issue.  This is definitely not a reliability issue related to Generator Interconnection. In a competitive market environment, the fact that there is more generation than load leads to economic congestion, which is addressed by MISO’s security constrained economic dispatch.

Longer term issues of continued market congestion are a sign that MISO’s Market Congestion Planning Studies and Market Efficiency Project (MEP) cost allocation are ineffective at solving consistent real time market congestion. Very few MEPs have been approved through the MTEP process largely because the MEP criteria are too limited.  MISO and stakeholders have a variety of options that would expand the opportunities for MEPs to mitigate congestion at existing generators, such as: 

• Add more economic benefit metrics to more accurately represent the savings that would accrue from building new transmission where the primary driver is reducing economic congestion.
• Reduce the required B/C ratio from 1.25 to 1.0.
• Evaluate the savings from transmission projects on a 40-year basis rather than 20 years, as 40 years is much more reflective of the actual life expectancy of transmission upgrades.
• Develop a more consolidated transmission planning process that can simultaneously address economic congestion, as well as reliability, interconnection, and public policy drivers in a more cost effective way.  LRTP is a step in this direction, but a more integrated solution that works to bring together MISO's siloed planning processes is possible.

Natalie McIntire

Respectfully submitted on behalf of the Environmental Sector

EDFR appreciates the opportunity to provide feedback on the Planning Subcommittee (PSC): Address Congestion at Existing Resources in Planning (PAC-2021-1) presented by MISO during the  April 27, 2021 PSC meeting.

While the focus of MISO’s MTEP Planning is to identify and address system congestion 5, 10, 15 year out, the real-time congestion across the MISO system continues to negatively impact generation assets and customers. In many scenarios, the anticipated in-service date of the MTEP identified projects are significantly drawn out or delayed resulting in exacerbating the real-time congestion.  For instance, the Wabaco – Rochester economic project was identified and approved in the 2019 planning year but will not be in-service until 2022. Hence, the congestion in this area continues to worsen and negatively impact generation assets and customers in the region. In order to alleviate such scenarios, EDFR suggests that MISO utilizes the real-time congestion data available and consider near-term operational remedies such as advanced line rating technologies, and temporary transmission reconfigurations. 

As it pertains to the transmission planning, a review of the upgrades coming from the planning processes and top constraints can identify opportunities for congestion mitigation either due to congestion getting worse compared to planning models, or due to outages associated with the planned upgrades. Furthermore, operational constraints with persistent congestion should be prioritized for mitigation even if not identified as constraints or candidates for upgrades in the planning processes. Better reimbursement mechanisms for sponsored upgrades and creating transparent processes for grid enhanced technologies to be proposed, assessed, and implemented for minimizing congestion/curtailments in the market. 

Additionally, EDFR encourages MISO to allow stakeholder presentations to  further discuss this topic in the stakeholder forum.

Regards,

Arash Ghodsian

Sr. Director Transmission & Policy

EDF Renewables

GRE Comments -  April 27, 2021 PSC Meeting 

Great River Energy appreciates the opportunity to provide comments to MISO on the following PSC item:

 “Address Congestion at Existing Resources in Planning (PAC-2021-1)”

•  GRE has a question and comment that we think will help in future discussions. Does MISO dispatch down existing resources with the same fuel type in order to accommodate new DPP cycle projects? For example, are existing wind projects dispatched down to accommodate new wind, when they are located in the same local electrical area? If this is the case, MISO and the PSC stakeholders should have a discussion if this makes sense moving forward.

• MISO Question #4 : Are changes needed to increase the appeal of Market Participant Funded transmission projects? MISO should consider a monthly or some other appropriate review period of congestion and determine if the congestion is long or short term. On short term congestion, we suggest implementing topology optimization for short-term relief, concurrent with MISO and stakeholders discussions of potential changes to long term planning processes, like existing economic planning that considers congestion.

May 13, 2021

Invenergy LLC ("Invenergy") appreciates the opportunity to comment on the proposal to address congestion at existing resources presented at the April 27, 2021 Planning Subcommittee.  

Respectfully, congestion is an economic issue, not a reliability issue and certainly not related to generation interconnection.   Economic congestion is addressed by MISO’s security constrained economic dispatch and relieving that congestion should be addressed through Market Efficiency Projects via the MTEP process.

Thank you,

Nicole Luckey

Vice President, Regulatory Affairs

Invenergy LLC 

• What "existing" generation resources should be considered (e.g. NRIS, ERIS, Conditional, Unconditional) in this discussion?
• We propose that all generation that is unconditionally interconnected be considered, and that all such generation should have a reasonable expectation that transmission planning will prevent significant deterioration of congestion conditions.  We recognize that deliverable resources, including both ERIS accompanied by firm transmission service and NRIS, merit special consideration given the importance of deliverability for resource adequacy.
  

• What real time congestion should be considered a reliability problem that needs [to be] addressed in reliability planning processes?
• Real-time congestion that impedes delivery of Capacity Resources relative to their availability as assumed in MISO’s capacity construct should be considered to constitute a reliability problem.　 We suspect this is a problem today.

• What specific planning process, if any, should be reviewed?
• Planning processes relevant to this issue appear to include, at least: generator interconnection; MTEP deliverability studies; and economic planning.　 Fuller consideration of potential congestion impacts in MTEP reliability planning and in LRTP may also be appropriate.

• If the FERC scope of ERIS and NRIS products are subject to congestion, should another service product be created?
• We would not propose a new product.  If MISO and stakeholders determine that changes to planning processes are not warranted to address this issue, we would turn our focus to operational remedies including advanced line-rating technologies and topology optimization, which we would suggest should not be assumed to be available in generator interconnection studies.　

• What specific changes should be made to MISO planning processes?
• We are open to suggestions from other stakeholders, but would suggest consideration of the following possibilities: appropriateness of 5% impact threshold for deliverability analyses; review of economic planning processes to consider why significant current congestion issues without known solutions are not identified and evaluated for possible solutions; consideration of a 'quick-hit' or targeted economic analysis internal to MISO; focus on addressing existing congestion in a timely manner in LRTP along with future resource-mix changes; and sequencing LRTP projects so as to most effectively reduce congestion during construction.

• Are changes needed to increase the appeal of Market Participant Funded transmission projects?
• As applied to the constraints with the primary impact on existing-resource congestion, the existing process for market-participant-funded projects appears to typically provide funders with less value than they provide to the market as a whole.  While we have no specific recommendations at this time, changes to increase the appeal of such projects merits real consideration.