PSC: Addressing Congestion at Existing Resources (PAC-2021-01) (20211012)

WPPI originally submitted this feedback at 9:57 a.m. on 11/1/2021, but it was not posted because of an issue with the Feedback Tool.  We re-submit those comments below.

WPPI gave the presentation that is the subject of this feedback request.  We have a number of follow-up comments.  To begin with we clarify a few points of confusion that emerged during the presentation:

1. WPPI absolutely recognizes the substantial value that ring-bus and other non-straight-bus substation configurations provide, and we did not suggest—nor would we—that ring buses should not be used.  Rather, our point was simply that, in a limited number of cases, opening a      ring-bus breaker during certain operating conditions can be a very effective way to address congestion issues without causing other material problems.  We suggest further that the MISO system would benefit from a regular process to evaluate potential benefits for such configuration changes, particularly when significant new facilities are placed in service.
2. We referred to the MISO-PJM Targeted Market Efficiency Project as a potential model for a process that could be undertaken entirely within MISO.  We are not proposing any changes to planning on the PJM seam.
3. We do not believe and did not mean to suggest that new facilities are not included in MISO’s post-in-service-date modeling.  Rather, our point was that we believe it would be beneficial to place more focus on new congestion patterns likely to follow significant transmission expansions, and on upgrades that may mitigate these new congestion  patterns.
4. We recognize that Transmission Owners, appropriately, have authority over facilities ratings and responsibility under FAC-011, and we are not proposing any change to this status quo.  We also recognize, however, that TOs may have some flexibility in setting ratings consistent with FAC-011 and other responsibilities, and we believe that rating adjustments may be a viable means for relieving constraints in some cases.  

WPPI has experienced very large costs from congestion that may be amenable to relief in the near term.  We reiterate the suggestion in the presentation that MISO should develop a regular mechanism for evaluating current and expected near-future congestion and considering both facilities upgrades and other approaches—such as system reconfiguration or ratings adjustments—that may provide congestion relief.  We expect that this could be a new MTEP process, an extension of existing economic planning within MTEP, or even, potentially, a process outside of MTEP.  

Madison Gas and Electric (MGE) IS particularly glad WPPI gave the presentation on addressing congestion at existing resources.  We’re in the same position as WPPI, sharing the some of the locations of heavy congestion of which he speaks.  Besides leading to significant curtailment of energy from our resources, it is this heavy congestion that most likely keeps us from getting firm transmission service from our wind farms that predate the GIP and back when we were prohibited from getting 100% NRIS for them.  That is, we could only be studied for 20% NRIS (80% ERIS) by Tariff. 

While it is quite possible we could have obtained 100% NRIS at reasonable cost, back in the day - over ten years ago, it is not possible to do so today.  We would likely be asked to pay for the network upgrades to relieve the very congestion WPPI outlines, thus making  and asking for the additional 80% of NRIS (to become100% NRIS) a fool's errand.

Given the new rules for capacity deliverability in the auction, we have tried unsuccessfully to procure firm transmission to fully qualify our resources for the PRA, but have been denied each and every time.

WPPI is not alone in its concerns and experiences.

GRE appreciates the opportunity to provide feedback to the PSC on this topic:

GRE has been experiencing very large costs from congestion. We therefore appreciate WPPI bringing this discussion to the PSC and support MISO looking further into potential solutions.

 We think there is value in evaluating how existing processes like the existing economic planning within MTEP can be leveraged to evaluating current and expected near-future congestion.

There would also be great benefit in evaluating the differences between market dispatch and planning and operating practices and studies to see if a new process would mitigate congestion patterns caused by construction outages related to generation network upgrades and other transmission expansions.

Transmission Owner Sector Feedback on October 12, 2021 Planning Subcommittee (PSC) on Congestion at Existing Resources (PAC-2021-1) Stakeholder Presentation

November 2, 2021

During the October 12, 2021 Planning Subcommittee (PSC) meeting, a stakeholder presented issues and options relating to Addressing Congestion at Existing Resources and included a proposal to add a targeted study to MISO’s transmission planning process based on historical congestion and “System Optimization” through reconfiguration and line rating adjustments.   Stakeholders were invited to provide feedback on the presentation, and the Transmission Owners Sector provides the following comments for MISO’s consideration.

Proposed Targeted Study Based on Historical Congestion

The Transmission Owners (TOs or Owners) agree that congestion at existing resources is an issue, but do not support the addition of a targeted study by MISO that would identify potential transmission projects based on historical congestion that did not also evaluate the potential for that congestion to persist into the future.  A primary concern with an additional study is that it is unlikely to resolve the underlying issue stemming from the disconnect between how interconnection studies are performed and MISO’s market dispatch, and this disconnect creates system congestion that may or may not be resolved by a project that is identified in the proposed study process.  These disconnects between interconnection and other transmission planning studies and market dispatch lead to system congestion:

• MISO’s market dispatch does not recognize the higher “priority” of Network Resource Interconnection Service (NRIS) firm injection rights relative to the non-firm rights injection rights of Energy Resource Interconnection Service (ERIS), however MISO’s study practices for ERIS build congestion into the system by applying a 20% DFAX when evaluating the need for system upgrades to reliability accommodate the injection of energy onto the system.  The higher DFAX essentially ignores 15% of the injection of energy by each ERIS resource, which translates to congestion.
• Unfortunately, NRIS is generally required for LSEs to meet MISO’s Resource Adequacy requirements, and requests for NRIS apply a DFAX of 5% to ensure the deliverability of the output of that generator to the MISO system, which results in increased costs for those generators from network upgrades required to accommodate deliverability outside of the local area, to the network.  Because MISO’s market does not recognize the priority injection rights of generators with NRIS, they are not able to compete with the price-point of ERIS units that are able to qualify for renewable production/investment tax credits that reduce the need for an off-taker that would require NRIS to meet capacity needs and applicable Local Clearing Requirements.  As a result, NRIS units are effectively priced out of the market by ERIS generators that create real-time congestion in the local area.

The Owners note that the issues described in the stakeholder presentation appear to be occurring in limited areas within MISO’s system and appear to be significantly influenced by the concentration of generators with ERIS vs NRIS in those areas.  Rather than creating another study to address system congestion occurring in real time operations, current processes and practices should be evaluated to determine how to best address the disconnect that is unfairly impacting capacity resources that LSEs are required to invest in to meet their Local Clearing Requirement under MISO’s Resource Adequacy construct.

For example, if these issues are not appearing in Futures models used for MISO’s long term Top-Down Planning studies, this needs to be evaluated because MISO uses historical congestion information gathered from market data to evaluate the flowgates that will be monitored in MISO’s economic planning studies.  If significant historical congestion issues do not appear in MISO’s economic models, it is either because there is a planned project to solve the issue or because there is an error in the way something is being modeled.  Even if MISO’s market data does not reveal a historically congested flowgate to be studied in a Market Congestion Planning Study stakeholders have the opportunity to recommend monitored flowgates for inclusion, so there is already an opportunity for these issues to be studied, when MISO performs these studies.

System Optimization (reconfiguration and line rating adjustments) 

System Optimization is generally achieved through system reconfiguration that involves removing a transmission element to direct flows and taking facilities out of service and does not generally improve reliability.  Additionally, it is difficult to study proposed reconfigurations for impacts on reliability and reconfigurations can be difficult to implement in operations, creating risk for other customers as well as system operations.  If MISO agrees to pursue system reconfigurations, MISO could need to ensure that reliability would not be impacted and must take responsibility for these impacts as the Reliability Coordinator.

Clean Grid Alliance Comments on Addressing Congestion at Existing Resources

November 2, 2021

Clean Grid Alliance appreciates the opportunity to provide comments on Addressing Congestion at Existing Resources. Clean Grid Alliance supports the concept of an “internal TMEP” process to facilitate building much-needed transmission on the MISO system. We encourage MISO to look seriously at implementing this request in a manner consistent with the MISO TMEP process that evaluates proposed seams projects using operations models and a cost/benefit ratio to justify construction of such projects. 

We sincerely thank MISO for the opportunity to comment on this topic, and look forward to further discussions. 

Sincerely,

Rhonda Peters, Ph.D.

Technical Consultant for Clean Grid Alliance. 

Alliant Energy is supportive of the WPPI proposal that MISO institute a new planning process focused on current congestion which could be addressed with near-term solutions.  We see growing potential value from increased focused on finding ways to address congestion with relatively quick and lower cost solutions.

The OMS Transmission Planning Work Group (TPWG) is generally supportive of MISO and stakeholders continuing to explore and prioritize work on this topic. This is OMS work group feedback, and the OMS Board has not considered its position on this issue.

 The OMS TPWG encourages MISO to identify safe and efficient solutions that could alleviate new and existing congestion wherever it occurs on the system. If resources are experiencing congestion differently now than they have historically, these stakeholders should have a formal process to review possible near-term solutions available to them. The OMS TPWG does not take a position on the value of a targeted study to better understand this issue at this time. However, the OMS TPWG looks forward to remaining engaged on this issue and notes its close connection to the OMS Board of Directors’ position on Enhanced Line Ratings.[1] The OMS Board is very supportive of novel approaches to cost-effective transmission system optimization.