PSC: Attachment Y Retirement Process BPM020 proposed changes (PAC-2022-1) (20221011)

ENVIRONMENTAL SECTOR COMMENTS TO PSC AGENDA ITEM 05a ON CHANGES TO THE SSR PROCESS UNDER BPM 20, § 6.2.5

The Environmental Sector appreciates MISO’s commitment to reliability in the face of increasing retirements.  If MISO believes that creating more SSRs is required to maintain reliability, of course, the Environmental Sector does not object.  However, the Environmental Sector is concerned that MISO is moving too slowly or may not be exploring all viable options in consideration of remedies for replacing the attributes lost from retiring units.  

SSR’s are simply a stopgap measure that is very expensive for load.  Rather than throwing money away on a costly stopgap measure, MISO should move as quickly as possible to facilitate viable, cost-effective, permanent solutions such as conversions to synchronous condensers combined with replacement renewable generation.

For example in the October 11, 2022 PSC meeting, the Environmental Sector asked that MISO create a comparison of timelines for the following events: 

1. Notification to MISO of intent to suspend/retire under Attachment Y; 
2. Deadlines for a unit moving from suspension to retirement; 
3. When Interconnection Rights are lost by a suspending/retiring generator; 
4. When a retiring generator would need to notify MISO of its intent to 
   • Replace its old generation with either solar, wind, or a battery; or 
   • Convert its old generator to a synchronous condenser.  
5. When MISO would complete its studies on 
   • Replacement generation; and 
   • Conversion to a synchronous condenser.
6. When MISO will notify others that the generator will be retiring

Understanding the above time sequences would demonstrate the ease by which an existing generator could continue to utilize its assets and provide needed “attributes” during this time of industry transformation. Given the sensitivity that MISO must place in maintaining confidentiality for certain retiring units, it is unfortunate that MISO would not at least commit to comparing these timelines and providing them to stakeholders. Such a comparison would not disclose confidential information, and it would better enable private parties to seek novel solutions.

We implore MISO to enable creative solutions to the challenges that it has identified in the RASC.  Enabling private capital to partner with retiring generators to ensure important attributes continue to support the grid appears to be a simple solution that MISO could easily enable. 

We appreciate MISO's efforts to be more transparent with the Attachment Y process. However, we believe the four 'transparency tables' do not go far enough and that the TOA should be modernized and made comparable to PJM to allow for disclosure of received retirement requests.