In the January 27 meeting of the Market Subcommittee (MSC) stakeholders were invited to submit feedback on using SATOA to Provide Market Services.
MISO discussed its proposal to pivot the approach to address SATOA market participation and related issues on a one-off basis.
Feedback responses are due February 17, 2022.
Clean Grid Alliance and American Clean Power Association Comments
SATOA Market Participation
February 17, 2021
Clean Grid Alliance (CGA) and the American Clean Power Association (ACP) appreciate MISO’s consideration of stakeholder input on this important and concerning topic presented at the January 27th, 2022, MSC meeting. MISO’s proposal to take a “one-off approach” to market participation of Storage as a Transmission-Only Asset (“SATOA”) resources is not appropriate and this topic will require significantly more stakeholder input and a FERC filing. In its presentation, MISO highlighted several cost allocation issues that have yet to be addressed for SATOA participating in the MISO market, as well as the need to clarify how operation as a transmission asset and as a market asset can occur without conflict. These are critical questions that should not be addressed on a case-by-case basis.
We strongly disagree with MISO’s proposal to address SATOA participation in the market on a case-by-case basis without going through a full stakeholder process to establish a solid framework and comprehensive FERC approved Tariff change on such a controversial and complicated topic. In fact, we submit that SATOA resources cannot participate in MISO’s market without a tariff filing approved by FERC. In its Order accepting MISO’s SATOA tariff filing, FERC expressly stated that “any proposal to allow storage facilities recovering cost-based revenues as transmission assets to also participate in these or other market activities will require an FPA section 205 filing with appropriate support, and intervenors will have the ability to protest such a filing.” [1] Accordingly, MISO must provide stakeholders the opportunity to participate in development of such a filing to address all the questions currently on the table related to this new resource type that potentially crosses boundaries between generation and transmission. And should MISO determine that market participation by SATOA resources is appropriate, it also must make a Section 205 filing at FERC.
When SATOAs were approved in the MISO tariff - granting exclusive rights for developing them to Transmission Owners only - the understanding, affirmed in FERC’s SATOA Order, was that SATOAs are considered transmission assets until such time as MISO works through the stakeholder process to address the key issues identified in MISO’s presentation. SATOA should not be allowed to participate in MISO’s market unless and until the proper Tariff and policy changes go through the stakeholder process and have obtained a final Order from FERC allowing them to do so. Doing otherwise would not be in line with the agreements and understanding within the stakeholder process to develop SATOAs in the first place, nor would MISO’s proposed approach meet FERC’s directives in its SATOA Order.
If MISO proceeds on a notionally one-off basis, it will set a precedent not just within its own footprint, but nationwide – and will do so without respect for its established process of addressing changes to its Tariff and FERC’s unambiguous instruction. Stakeholders will be impacted and must have the opportunity to review and provide feedback on SATOA market participation, and FERC must have the opportunity to evaluate any such tariff changes. Policy should be made in an open and transparent way, and history has shown that the stakeholder process often results in an improved outcome when all perspectives and suggestions are considered.
Finally, MISO has continually made it clear how resource-constrained it is, especially regarding staff working on the new Market System Enhancement and implementing Orders 841 and 2222. It seems that being short staffed may be one of the drivers behind short cutting the process to develop comprehensive tariff rules for SATOA market participation. SATOA market participation is optional and is neither a reliability function nor a critical market task. In fact, there are no SATOAs in the interconnection queue at this time. This suggests that there is no urgent need to develop SATOA market participation rules. MISO staff should suspend the SATOA market participation effort and focus on the critical functions of the already delayed and costly Market System Enhancement and other FERC-mandated market features under Orders 841 and 2222. There are over 14 GW of stand-alone storage and over 12 GW of storage hybrid resources in the MISO queue that urgently need market participation rules in place. MISO needs to prioritize its limited staff resources to ensure full storage market participation is implemented before beginning the conversation on SATOA market participation.
We strongly encourage MISO to take a step back from its proposed “one-off approach” to allow SATOAs into its marketplace. With no SATOAs in the queue, a pause would be appropriate at this time. When market rules for SATOAs are needed MISO must engage in a robust stakeholder process to establish a comprehensive proposal for this change to its market design, one that will establish an important precedent that will have long-lasting and far-reaching impacts and consequences both within and outside of MISO.
Sincerely,
Rhonda R. Peters, Ph.D.
Technical Consultant to Clean Grid Alliance
Natalie McIntire
Technical and Policy Consultant to Clean Grid Alliance
Daniel Hall
Central Region Senior Director, Electricity & Transmission
American Clean Power Association
Jason Burwen
Vice President, Energy Storage
American Clean Power Association
[1] Midcontinent Independent System Operator, Inc., Order Accepting Tariff Revisions Subject to Condition, at P117, 172 FERC ¶ 61,132 (2020) (“SATOA Order”) (emphasis added).
Consumers Energy appreciates the opportunity to provide feedback on using SATOA to Provide Market Services.
CE generally supports DTE Energy's feedback.
CE does not support a one-off approach to allow SATOA market participation because it sets an undesirable precedent for future projects that does not ensure comparable and fair treatment for all SATOA resources. In addition, FERC Standards of Conduct rules need to be addressed before SATOAs can become market participants.
MISO should prioritize Market System Enhancements to allow full ESR participation under Order 841 and prioritizing reviews and studies to expedite processing of storage and other resources in the Generator Interconnection queue to become more familiar with storage resources on the MISO System in general that will support the conventional, comprehensive policy approach required to address SATOA providing market services.
Savion, a Shell Group portfolio company operating on a stand-alone basis, is an industry-leading solar and energy storage organization built on a foundation of specialized experience and mastery in the craft of development. With a growing portfolio of more than 19GW, Savion is currently one of the country’s largest and most technologically advanced utility-scale solar and energy storage project development companies. Savion’s diverse team provides comprehensive services at each phase of renewable energy project development, from conception through construction. Savion is committed to helping decarbonize the energy grid by replacing electric power generation with renewable sources and delivering cost-competitive electricity to the marketplace.
Savion, LLC would like to thank MISO for bringing this item to stakeholders for discussion. In the January 27 meeting of the Market Subcommittee (MSC) stakeholders were invited to submit feedback on using SATOA to Provide Market Services. MISO discussed its proposal to pivot the approach to address SATOA market participation and related issues on a one-off basis.
Savion is generally in agreement with MISO’s current BPM and rules where SATOA is approved via the Transmission Planning Process and compensated through tariff rates and ESRs are approved through the GI process and compensated through the markets.
However, the new proposal to allow ‘one-off’ approvals for SATOA to access the market cannot be viewed as anything but discriminatory, irrespective of FERC Policy Statement PL17-2-0000 or the Western Grid Declaratory Order EL10-19-0000.
The reasons for this are simple, 1) only TOs will have access to this approval method 2) TOs will have a vested interest in securing swift approval through affected system studies and might arbitrarily change (or not change) parameters to match neighboring systems, unlike the experience IC face in similar circumstances, 3) all construction risk for TO-based development is guaranteed a ROR from the tariff and no IC can compete with that financing advantage.
Lastly, MISO has delayed implementation of 841 which effectively shut off IC access to the queue using a clear process. While TOs already have a clear process to approval through the transmission planning process, ‘one-off’ approvals would better be afforded to the ICs that have been disadvantaged by MISO’s three-year delay in 841.
Savion looks forward to being an active participant in these discussions.
Thank you for the opportunity to provide feedback on using SATOA to provide markets services and on MISO’s proposed approach to address SATOA market participation and related issues on a one-off basis.
DTE opposes the one-off approach as it lacks the transparency and collaboration that is fundamental to MISO’s values and the stakeholder process in general. Using a one-off approach to SATOA participation in the energy markets sets an undesirable precedent for future projects. Based on projected industry trends, future interest in participation in the SATOA market is likely to be greater than current interest and should be prepared for accordingly. Will this one-off approach be permanent or are there plans to develop a comprehensive policy approach in the future? Rather than deferring development until there is more substantial interest, MISO should proactively use this stakeholder process to develop a viable path which would ensure comparable and fair treatment for all SATOA resources.
Fundamentally, SATOAs that seek to participate in MISO’s markets should be treated comparably to all other resources seeking to participate in MISO’s markets. Developing a service agreement on an individual basis, behind closed doors, could significantly favor specific outcomes and perpetuate unfair treatment. The extent to which SATOAs can be interconnected to participate in MISO’s markets will be heavily dependent on the associated assumptions and therefore, these decisions and assumptions should not be made in a way that favors a specific SATOA owner or outcome. How will MISO address these concerns within the framework of a one-off approach? Additionally, how will MISO ensure that the one-off approach meets MISO’s commitments to develop operating and business practice manuals regarding SATOA market participation?
MISO acknowledged, and DTE agrees, that multiple design elements will require more work before SATOAs can provide market services. In addition to the items discussed at the 1/27 MSC meeting, DTE offers and reiterates the following issues that must be addressed in considering any proposal that allows SATOA to also provide market services.
Any proposal must ensure incumbent transmission owners cannot unduly discriminate in favor of their own resources.
Market participation by SATOAs raises significant concerns around violations of FERC’s Standards of Conduct that need to be addressed.
All storage assets, including SATOAs, will need to proceed through the Generator Interconnection Process to participate in the MISO markets.
All SATOAs that provide market services will need to balance market participation with obligations to transmission customers.
MISO’s SATOA construct implies that storage that qualifies as SATOA is first and foremost a transmission asset. As such, a SATOA which would seek to participate in MISO’s markets must demonstrate that this participation will not harm or degrade the SATOA’s ability to provide the reliability service it was approved for and that transmission customers are paying for. How will the one-off approach address this issue?
DTE believes all issues discussed above are best addressed with the conventional and comprehensive policy approach, including development of Tariffs, business practices manuals and operating guides.
Minnesota Power recognizes and supports MISO's efforts to prioritize staffing and resource allocation on high priority items. However, we are concerned that developing one-off, individual service agreements to allow market participation for a SATOA may have unintended consequences in the future. Until we understand how MISO will incorporate, provide transparency and limit terms, for these individual service agreements to ensure alignment when future Tariff changes are made, we cannot support the proposal as presented by MISO at the January 27th Market Subcommittee meeting. Further, MISO has not identified a timeline for taking up this policy work in the future. Once a full time line is defined, market participants would be able to provide additional feedback on the issue.
MPPA generally supports WPPI's feedback.
Thanks,
David Sapper
Customized Energy Solutions
dsapper@ces-ltd.com
WPPI supports MISO’s approach to move forward now with a service agreement approach to govern the participation of Storage As a Transmission Only Asset in MISO market for the following reasons:
WPPI’s support for a service agreement approach assumes MISO will incorporate this approach into its tariff (as well as its Business Practices Manual(s)) and the service agreements themselves will be filed with FERC.
Lastly, WPPI, as a load serving entity (with load in 3 MISO transmission pricing zones), is interested in facilitating SATOA participation in MISO markets now in order to potentially reduce the cost of serving load as well as reduce transmission rates.