PSC: Dispatch of Energy Storage in MTEP and DPP Studies (20220412)

EDF Renewables (EDFR) supports the proposed changes to standalone storage. We do not however support proposed changes to Hybrid Facilities incorporating batteries. For other hybrid projects dispatch is determined based off of fuel type dispatch of each individual fuel type comprising the hybrid. Not doing such for storage appears to be discriminatory towards said storage projects. Additionally, this incentivizes not having hybrid projects involving batterie, but instead have two separate projects.

Thank you for the opportunity to provide feedback

Jupiter Power was unable to participate in the April 12 meeting of the PSC.  We reviewed the presentation and truly appreciate MISO taking effort in revising the dispatch assumptions to reflect BESS operational characteristics.  We support removing BESS discharging scenario in the shoulder peak case.

However, we suspect removing charging scenario in the shoulder case in the DPP process and having BESS charging studied in a separate TSR process creates a meaningful barrier for standalone battery storage projects relative to hybrid facilities and other technology.

For standalone battery storage projects participating the wholesale market, the energy charged from the grid is stored energy which will be returned to the wholesale market later.  In other words, the nature of BESS charging is very different to network loads as the BESS is not serving the end user and is no different from pump storage generating facilities. For this reason, we recommend removing the TSR process required for the BESS charging and having BESS charging study incorporated in the DPP study process.  We believe our recommendation is to give standalone BESS interconnection similar treatment to other technology so long as the BESS is not intended to serve onsite retail load or end user.  Having BESS charging study streamlined in the generator interconnection process without additional TSR process is commonly adopted in other RTOs.

Transmission Owner feedback on Proposed modifications to BPM-015 and MISO MOD-032 Manual Regarding Storage in MTEP and DPP, presented at the April 12, 2022 Planning Subcommittee (PSC)

April 29, 2022

During the April 12, 2022 Planning Subcommittee (PSC) meeting, feedback was requested on proposed modifications to BPM-015 and MISO MOD-032 Manual regarding the dispatch of storage in MTEP and DPP study models.  The MISO Transmission Owners support MISO’s approach but suggest that stakeholders and MISO continue to review operating data to evaluate whether future adjustments to the dispatch levels or may be needed.

Additionally, the BPM-015 fuel-type dispatch table should clarify how co-located resources that are not operated in a Hybrid mode will be modeled, and with regard to Hybrid Resources, it would be expected that the storage would be dispatched to inject the to the level of the interconnection service not met by the non-battery resource.

Alliant Energy again thanks MISO for the time and effort spent on reviewing storage modeling assumptions.  MISO’s proposed change to the assumed dispatch for stand-alone battery storage is an improvement over current assumptions used.  Alliant Energy also believes there is value in continuing to monitor and consider how storage dispatch assumptions may need to further evolve.  For example, hybrid resources that include storage can be combined and operated in multiple ways.  It will be important to ensure that MISO’s assumed dispatch of storage, including storage part of hybrid resources, is aligned with how these resources are anticipated to operate.

The Environmental Sector appreciates the opportunity to provide comments on the Dispatch of Storage in DPP and MTEP studies. Aligning storage dispatch in planning studies with how it is dispatched operationally will allow for more accurate modeling. We support MISO’s proposal and encourage expedited implementation. Although MISO has not proposed to change storage dispatch in hybrid projects, we believe there is value in doing so, and particularly in separating wind+storage from solar+storage. We encourage MISO to go through the same effort with hybrid projects (differentiated between wind and solar hybrids) as it has with stand-alone storage.

Clean Grid Alliance Comments on Dispatch of Storage in MTEP and DPP Studies

April 29, 2022

Clean Grid Alliance appreciates the opportunity to provide comments on Dispatch of Storage in MTEP and DPP Studies. We applaud MISO’s effort to remove unnecessary barriers to bringing storage resources online. We appreciate MISO’s consistency in equal treatment of dispatch changes regardless of fuel sources. Gas turbines and solar were previously changed based on available data, and as storage is proposed now. 

Although MISO did not include hybrid projects involving storage for a change in dispatch, we believe that it merits consideration. In particular, there are significant differences in operations between solar + storage and wind + storage that warrant further consideration

We fully support this change, and encourage MISO to incorporate it into the 2021 DPP cycle and to also evaluate separately data available for hybrid solar + storage and wind + storage in the near future. 

Savion, LLC (“Savion”), a Shell Group portfolio company operating on a stand-alone basis, is an industry-leading utility-scale solar and energy storage project development company.  Savion would like to thank MISO for bringing this topic to stakeholders for discussion.

Savion agrees with MISO’s proposed approach on this topic.  Savion holds That all simulations of ESR should be updated as a more robust understanding of their actual operation is gained in the years to come.

Savion appreciates the opportunity to participate in further consideration of this matter.

MidAmerican Energy Company (MEC) agrees with the operational data in the April 12^th, 2022 PSC presentation and supports the proposal to study storage resources at a 0% dispatch in the shoulder case beginning with the 2022 cycle.

However, MEC does not agree that batteries (or other storage resources) in a hybrid facility should be studied at a 100% dispatch as compared to storage as a standalone resource at a 0% dispatch in the same shoulder case. Similar to storage as a standalone resource, storage in a hybrid configuration is designed with a control narrative to decrease congestion at the point of interconnection, thus, decrease the need for new transmission. MEC does not believe a hybrid configuration will affect the dispatch of the storage resource as compared to a standalone storage resource in close proximity.

As a result, MEC suggests all new storage facilities in the shoulder case should be studied at an equal dispatch of 0% as a standalone storage resource.

Enel appreciates this opportunity to provide feedback on the Dispatch of Energy Storage in MTEP and DPP Studies. Enel supports the changes presented at the PSC on April 12. The new policy more accurately represents real world operation of batteries. Enel appreciates MISO efforts on this issue.

WEC Energy Group was unable to participate in the April 12 meeting of the PSC.  However, our review of the Dispatch of Storage in MTEP and DPP Studies presentation resulted in some confusion and we suggest the following improvements.

1. Within the proposed BPM-015 language, it is helpful to include a footnote regarding co-located resources that are not operated in a Hybrid mode.  Our understanding is that each co-located resource not registered as a Hybrid is dispatched per the non-Hybrid resource type in the fuel table, up to the applicable interconnection service.  We believe that BPM-015 should explicitly reference the dispatch assumptions for co-located resources that are not operated as a Hybrid.
2. The redline language in Footnote 13 should be modified to include the following - "This is inclusive of Surplus, Replacement, and Generation expansion requests that incorporate additional fuels and are registered as a Hybrid Resource".
3. The Hybrid Facility dispatch assumptions are confusing.  At summer peak and shoulder peak, we expect the Hybrid Facility to dispatch the non-storage resource per the fuel table and the battery up to 100% based on the amount of interconnection service.  The reference to "Battery 100%" is confusing.  We expect the battery within a Hybrid Resource to fill in the difference between the non-battery dispatch level and the total interconnection service.

WPPI appreciates the operational data provided by stakeholders and compiled by MISO relating to expected operational patterns of battery storage resources.  It is reasonable to assume that battery discharge will be relatively low during low-price conditions.  WPPI believes MISO’s revised proposed dispatch for stand-alone battery storage is reasonable and is an improvement on the status quo.  We appreciate the observation that battery storage that is part of a renewable-hybrid installation may tend to operate differently than stand-alone storage, and we see the proposed 100% shoulder-peak dispatch for solar-hybrid batteries as reasonable.  We do suspect, however, that when wind is experiencing peak output, associated hybrid battery storage would be unlikely to be also dispatched at 100% in any conditions where this would contribute to congestion.  Accordingly, we would recommend that stakeholders and MISO continue to review operating histories and consider possible revisions to the proposed shoulder-peak dispatch level of 100% for wind-hybrid battery storage, given that wind output is also assumed to be 100% in these cases.

SunEnergy1 supports the proposal MISO made at the 4/12 PSC. Compared with the existing dispatch, this proposal better represents the reality. Also, leaving the charging study to TSR/MTEP study aligns with how other load interconnections/additions are processed/studied. (Note that a load can also be part of an LSE's network load growth which is handled as an integral part of MTEP where a TSR is not required.) The current misalignment already created issues/questions. SunEnergy1 supports all components of this proposal and thanks MISO for the opportunity of providing feedback.