During the June 22, 2021 Planning Subcommittee (PSC) meeting, MISO reviewed draft language changes for Storage as Transmission-Only Asset (PAC004). MISO is requesting Stakeholder feedback on the following:
Please provide feedback by July 16.
Transmission Owner Sector Feedback on Draft Storage as Transmission-Only Asset BPM-020 language, Eligibility Checklist, and Life-Cycle Cost Estimate Spreadsheet
July 16, 2021
During the June 22, 2021 Planning Subcommittee (PSC) meeting, MISO reviewed draft language changes for Storage as Transmission-Only Asset (PAC004). MISO is requesting Stakeholder feedback on the following:
The Transmission Owners thank MISO for the opportunity to comment and provide the following feedback with regard to the revisions proposed for the BPM for SATOAs:
The Transmission Owners note that the proposed BPM language does not include a section regarding the “Evaluation” of a SATOA. Proposed Section 2.3 of BPM 20 says that “The process to evaluate electric storage facilities as SATOA in the planning process is further described in Appendix A of this BPM” but the language in appendix A does not describe the evaluation.
Section A.2, SATOA Approved in Prior MTEP Cycles – The Transmission Owners believe the revision proposed by MISO should be revised as shown below: (Suggested alternative language)
If an existing or MTEP-approved SATOA is to be evaluated in a current MTEP cycle to resolve additional transmission issues, it must be shown that the SATOA can resolve both the original and the additional transmission issues that it was originally installed to resolve, or that the SATOA can modified to resolve both original and additional transmission issues as part of the current MTEP cycle.
A3.3 - Selection of SATOA as a Preferred Solution in MTEP
Suggested addition or modification: In order for a SATOA to be selected, it must be shown to provide a superior solution compared to other potential transmission alternatives when all relevant benefits are considered.
A3.4 - Transmission upgrades required as a result of SATOA impacts on resources in the Interconnection Queue
The proposed revisions to BPM-020 have identified that for a SATOA if MISO or a stakeholder identifies that the potential impact in a DPP study of adding a SATOA in an MTEP cycle is to increase network upgrade costs to generating Facility, MISO will identify the potentially impacted generation facilities and compare the loading impacts with and without the SAOA in the MTEP model. The costs of mitigation of any issues will be included in the cost evaluation of the SATOA and would not be assigned to the generator.
A.5 Retirement of SATOA
Proposed language:
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. Any SATOA facility retiring as a transmission asset that desired to operate as a resource must obtain a Generator Interconnection Agreement to operate and follow the MISO Generator Interconnection Procedures.
Comments relating to GI applications for SATOAs:
The Owners request that MISO add BPM-015 to the list of other BPMs that may or will require updating to reflect the use of a SATOA or other storage applications as mitigation in the Generator Interconnection Process (GIP). Additionally, there is a need for the PSC to address these applications in the GIP specifically, beginning with a discussion of what GI issues have the potential to be addressed by a storage solution; process concerns should not be discussed until it has been established that such potential exists.
AES Indiana generally supports MISO's revisions to its SATOA BPM language and appreciates MISO's effort to incorporate AES Indiana's concerns.