In the November 29, 2022, meeting of the Planning Advisory Committee (PAC), MISO presented proposed BPM-015 language for ERIS Distribution Factor (DFAX) reduction for stakeholder feedback.
Comments are due by January 6.
Pine Gate Renewables (Pine Gate) appreciates the opportunity to comment on MISO’s ERIS DFAX Reduction Proposal. Pine Gate does not support this proposal, disagrees that there is sufficient support for this proposal, and is concerned this proposal will lead to unintended consequences for both generators and transmission owners and is, hence, unnecessary. In response to this request for feedback, Pine Gate reiterates its opposition and reasons therefore as submitted in its previous feedback, supports the comments provided to MISO by the Clean Grid Alliance, and provides the following additional comments:
NextEra Energy is not supportive of the DFAX change as proposed. As one of the largest generator owners, NextEra is very supportive of finding solutions to issues that current generating assets face, as well as assets that will be built in the future, however MISO and proponents of the DFAX change have not demonstrated that this change has any positive impact on congestion or that the benefit would come near or exceed the cost of the additional upgrades that would be identified.
NextEra would like to encourage MISO to perform a study which identifies benefits of this policy change at various DFAX levels and how that will impact the congestion on the system instead of forcing through a change that results in an unknown outcome.
Invenergy appreciates the opportunity to provide feedback and respectfully submits the following comments to the ERIS DFAX Reduction Proposal.
Invenergy shares stakeholder concerns about congestion and encourages model assumption improvement through a transparent and collaborative environment. After several rounds of feedback with many stakeholders requesting increased visibility on the ERIS DFAX reduction proposal, Invenergy still finds that the problem statement is too broad and that the analysis provided to date is insufficient to support the proposal. Until the benefits and expected impacts of this decision have been clearly defined, Invenergy cannot support the proposal to decrease the ERIS DFAX from 20% to 10%.
The proposal progressed through the stakeholder process without addressing stakeholder concerns about the problem, effectiveness, and impact of the change. From the first comment opportunity in August, many stakeholders extensively reviewed the proposal and asked for further justification. The only analysis provided described the number of facilities that would be identified at different DFAX thresholds, which demonstrates only correlation and not causation.There has still been no analysis or rationale to justify a 10% threshold as compared to other thresholds, apart from a blanket statement that it “strikes the right balance.”
Weighing the effectiveness of a solution is impossible without a common understanding of the problem. When the issue first entered the stakeholder process, the change was aimed at reducing congestion, which is out of scope for the interconnection process. However, the rationale presented with MISO’s support of the proposal was based on reliability concerns. Stakeholders have not seen any analysis, outside the existence of congested flow-gates, that demonstrates that the current 20% ERIS DFAX threshold is driving reliability issues across the footprint.
Invenergy urges MISO to provide a concrete problem statement, a set of criteria, and analysis which demonstrates causation and not just correlation, all of which are necessary for a robust stakeholder process. Invenergy once again encourages MISO to draw inspiration from SPP’s “HITT T1 ERIS Study Scope” approach to define the appropriate study scope and objective.
Even if this change is implemented through the BPM, the proposed change would have a substantial impact on all stakeholders and should not be made hastily. Lowering the DFAX threshold would be particularly impactful for interconnection customers’ commitments, financial requirements, and development strategies.
Invenergy thanks MISO for their consideration.
Clean Grid Alliance Comments on ERIS DFAX Reduction Proposed BPM Language
January 6, 2023
Clean Grid Alliance appreciates the opportunity to comment on the proposed ERIS DFAX Reduction Business Practice Manual (BPM) language change. We continue to have serious concerns regarding this proposal being addressed as a BPM edit rather than a Tariff filing where we believe it appropriately belongs. MISO has undertaken zero study effort to demonstrate that this change will be effective and it has yet to perform any due diligence in quantifying the magnitude and number of unintended consequences that will ultimately result. These consequences include raising overall costs to load and impacting resource adequacy by causing the withdrawal of generator interconnection requests that otherwise would have been able to complete the generator interconnection process, among other negative impacts.[1]
Clean Grid Alliance verbally shared at the October 2022 IPWG and the November 2022 PAC, recommendations on what studies/data at a minimum, must be provided to justify a change in DFAX. Performing a PROMOD congestion study to identify the impact this proposed change will have on congestion, along with any generation cost increases to load resulting from additional queue withdrawals is needed to understand this change at the most basic level. Specifically a PROMOD run to compare congestion at 10% and 20% DFAX on a previously completed DPP study group can give a good indication of whether this change would actually achieve its intended purpose or not. Creating an accurate PSS/E powerflow model input to the PROMOD run is critical for accurate PROMOD results. Generator interconnection projects that had completed the DPP study process and reached commercial operation, but that would not have been able to complete under the new rules, would need to be removed from the PSS/E model input to PROMOD[2]. However, to date, MISO only looked at a Phase 3 System Impact Study and estimated the increase in number of Network Upgrades at that time in the process. MISO has not attempted to apply the threshold change in Phases 1, 2, and 3 of a completed DPP study or to remove the projects in each phase that go above a reasonable $/MW threshold. MISO’s failure to implement this relatively simple analysis has not been adequately explained, and would result in a rushed change without meaningful data to support it. Reduced competition and increased generation costs could well result in cost increases to load at the end of the day that might even surpass any savings in congestion. A proper PROMOD study would provide actual data on the implications of a DFAX change.
Further, addressing congestion through GI studies is a paradigm shift above and beyond addressing reliability and the method proposed by MISO significantly erodes the ERIS project. It should be under FERC purview as part of a Tariff revision to determine if it is just and reasonable or even a helpful change, at the end of the day. Additionally, no reliability gaps have been identified that can justify this change. Making this change in a BPM instead of the Tariff appears to be a means to avoid as CGA does not believe that MISO’s analysis to date could satisfy the minimum standards required to justify such a proposal under Section 2015 of the Federal Power Act.
Additionally, we note that lowering the DFAX in combination with a separate MISO BPM proposal to create a new “like for like” barrier for including Long Range Transmission Planning lines in DPP study models will further drive new generators to withdraw that otherwise would have completed the DPP process. The cumulative impact of these two proposals together is significant and quantifiable, and should be investigated and reported on by MISO.
On a minor detail, MISO may want to consider defining the term “MISO Midwest” in Figure 6-2 and/or Sections 6.5.3 and 6.5.4 of BPM 15.
In conclusion, we strongly encourage MISO to reconsider its approach on this DFAX proposal and take the necessary time and steps to adequately study it and then justify it as Tariff filing, if the data supports such a change.
[1]MISO's RRA assessment indicates projected Capacity shortfall https://cdn.misoenergy.org/20220824%20RASC%20Item%2006%20Regional%20Resource%20Assessment%20Presentation626035.pdf. ERIS reliability studies are required for all NRIS projects. With this proposed change, some NRIS and ERIS generator interconnection projects that otherwise would have completed the MISO interconnection process will no longer be able to complete, therefore impacting Capacity and other markets. Furthermore, the full extent of costs to load is not limited to congestion alone, but a combination of the cost of generation plus congestion. Costs to load must be looked as a whole, through a PROMOD study, not just one cost element in isolation. Lowering costs in one area can raise them in another such that a net loss will occur. Since congestion is often associated with the availability of low cost generation due to a competitive market there, are push-pull forces at play.
[2] The exercise of removing projects in Phases 1, 2, and 3 of the DPP that would surpass a $/MW threshold and withdraw from the generator interconnection process at 10% DFAX but were able to complete the process at the 20% DFAX level would also provide data on one unintended consequences that will result from lowering the DFAX.
Steelhead Americas continues to be opposed to any change in the DFAX used in MISO’s DPP studies. Regardless of whether being framed as an economic or reliability issue, MISO has still not shown the existence of a problem needing their proposed ‘solution’.
For economic congestion, no linkage between DPP study generators and real time congestion has been shown. Further, the proposed ‘solution’ has not been shown to be effective in reducing congestion.
On the reliability side, it is a self-fulfilling statement when MISO says they’ve identified additional “reliability issues” when lowering the DFAX. In the same manner, we can eliminate “reliability issues” by raising the DFAX to 25%. These ‘issues’ have not been considered as such for the past 10+ years and MISO has not shown that they are present in other reliability processes.
SunEnergy1 appreciates the opportunity of providing feedback. SunEnergy1 does not support DFAX change in ERIS studies. This change is not just or reasonable. It will increase the overall cost of serving MISO load by preventing market competition. Further, it will greatly hamper renewable resource development in the MISO region and endanger MISO states’ renewable goals. It goes against the direction of FERC and DOE’s interconnection/transmission reform effort from ANOPR and i-2X. It is a U-turn from MISO LRTP and JTIQ initiatives which have been deemed by the entire country as the best practices to enable renewable resource’s development in meeting the nation’s clean energy target.
Please note that MISO ERIS criteria are already more stringent than other RTO’s. Among the 7 RTO in the US, only SPP and MISO require ERIS requests to make network upgrades to fix regular N-1 thermal constraints that are monitored/mitigated in the energy market through regular market clearing. ERIS resources (or Energy-only resources as called in some RTO) are considered “non-firm”, and market redispatch should be considered as valid mitigations. While MISO does not need to be consistent with most RTO's, MISO needs to be careful by going to the other extreme which will prevent healthy market competitions, distort market price signal for long term investment (resource siting), and endanger MISO states’ renewable goals.
We would also like to remind everyone that the proposal was originally brought to IPWG by Xcel, but Xcel’s congestion analysis was misleading because it was not related to the cost of serving MISO load. The congestion cost in the presentation was a result of more low-cost resources available. It is not regarding the actual cost of serving MISO total load. The overall MISO load is actually paying less due to market competitions. More importantly, in either case the load is served and Xcel has not demonstrated why this is a reliability issue rather than an economic issue. If the overall market sees economic benefits solving these constraints through transmission upgrades, it belongs to the overall transmission planning process rather than each individual new resource’s interconnection process. Please note, normally congestions provide healthy and necessary price signals for future resource and load siting strategy.
SunEnergy1 urges MISO to reconsider this proposal and pay attentions to the unintended consequences.