During the April 12, 2022, Planning Subcommittee (PSC) meeting, MISO discussed revised BPM language and the Non-Transmission Alternative submission form. MISO is requesting Stakeholder feedback on the language and form presented.
Please provide feedback by May 6.
DTE appreciates the opportunity to provide feedback to MISO on the topic of converting retired generators to a synchronous condenser unit (SCU). While DTE commends MISO for being open to evaluating these opportunities through the existing Attachment Y and MTEP processes, we are concerned that MISO’s condition that the generating asset be converted to a transmission asset will limit the application of this option within Zone 7 due to the unbundled nature of Transmission and Generation in the state of Michigan. With this condition in place the transmission system is at risk of being unnecessarily sub-optimized from both a reliability and cost perspective. Due to the unique ownership structure of Transmission and Generation in the state of Michigan a unique solution should be adopted to accommodate these situations and allow MISO and Stakeholders to pursue the appropriate solutions to optimize grid performance. To justify its decision to limit these opportunities as transmission assets MISO lists the following drivers:
1) How the equipment output is consumed, specific to how the Transmission Operator communicates the need for voltage support
2) Market products, none exist or are on the near-term horizon to facilitate this need
3) Technical characteristics of equipment
4) Non-Transmission Owners can submit transmission alternatives
As it relates to the first point the current process for communicating voltage support could continue regardless of the asset classification. As it is managed today, the Generator Operator is responsible for maintaining voltages within the thresholds established by the Transmission Operator. There is absolutely no reason in which the current process could not be employed under a scenario in which the Generating Owner retains ownership of the converted generating unit. DTE would recommend continuation of this process as it would continue to support voltage requirement needs and provide MISO and Stakeholders with the flexibility to analyze retired generators as a Non-Transmission Alternatives.
In reference to MISO’s second point, establishing a market product for reactive power should not preclude MISO from allowing retired generator units from remaining a generating asset as the compensation for reactive power can follow the same cost-based approach that is outlined in the Schedule 2 of the tariff for System Support Resources until a market product can be developed. The decision to then develop a market product for reactive power would be (and should be) independent of the decision to allow generators to retain ownership of retired generators that have been converted to SCUs.
In response to the third point, the technical characteristics of the equipment presents more reason for the asset to be owned and operated by the Generating Operator versus the Transmission Operator due to the Generating Operator’s familiarity with the equipment. In fact, it is very likely that the Transmission Operators would be reluctant to take ownership and operate the asset rendering the option to convert a retired generator into a SCU as non-viable.
As for the final point, if converting a retired generator into a SCU is the best solution from both a reliability and cost perspective then MISO should work with Stakeholders in eliminating the barriers to leveraging these opportunities. Additionally, limiting Non-Transmission Owners to submitting transmission alternatives directly contradicts FERC Order 1000 which states the Transmission Providers obligation to give “comparable consideration” to non-transmission alternatives.
In closing, DTE recommends that MISO be more flexible and accommodating to non-vertically integrated utilities that have interest in converting retired generators into SCUs but no ownership in transmission assets. DTE encourages MISO to work with Generators and Transmission Owners to establish procedural mechanisms that give “comparable consideration” to the use of retired generators as synchronous condensers to all MISO utility members. Doing so not only allows the process to operate within the spirit of FERC Order 1000, but it also allows MISO and Stakeholders to ensure the right solutions are evaluated to optimize the transmission system from both a reliability and cost perspective.
The Environmental Sector supports MISO’s efforts to enhance consideration of non-transmission alternatives (NTAs) and the opportunity to comment on MISO’s proposal presented to stakeholders at the April 12th Planning Subcommittee meeting.
Initially, we want to express our support for MISO’s proposal to shift the consideration of NTAs earlier in the process with NTA eligibility to be posted with the SPM1 materials rather than with the SMP2 materials. This should facilitate timely submission of NTAs and provide time for due consideration alongside traditional transmission solutions. Providing this information earlier is a critical step to putting NTAs on equal footing with other transmission solutions. We encourage MISO to move forward with this proposal as an initial step towards proper consideration of NTAs.
However, simply shifting NTA consideration to earlier in the process is not sufficient to ensure proper submissions and consideration of NTA solutions. The simple fact is that current financing, cost-recovery, and incentive structures do not provide proper incentives to MISO transmission owners to seek out and submit cost-effective NTA solutions that might provide cost savings to consumers while meeting the needs of the system.
To help overcome these systemic barriers to cost-effective NTA solutions, we encourage MISO to be more proactive in its identification of NTA opportunities. Simply waiting for MISO transmission owners and other stakeholders to submit NTAs is not an appropriate position for MISO to take when it’s clear such a stance will not lead to the identification of cost-effective NTAs. MISO should be transparently considering NTAs in its own processes for identifying solutions to reliability issues and should bring that information back to stakeholders for consideration. We understand that MISO does not have the authority to require its Transmission Owners to construct NTAs, but identifying them as an alternative solution may help state regulators, utilities, and others pursue these opportunities, which are likely to save consumers money. We encourage MISO to move forward with a formal process for review and identification of NTAs as part of its transmission solutions review process.
Specific to MISO’s proposal regarding the conversion of retiring generators to synchronous condensers (SCs) as transmission assets, we support MISO’s consideration of SCs as Non-transmission alternatives and its effort to clarify a process for their consideration. However, important questions must be answered before MISO takes formal action. For example, we do not have clarity on how conversions to SCs will impact interconnection opportunities at and around the point of interconnection for those retiring generators. We are also interested in exploring how the conversion to SCs may delay environmental remediation efforts at retired coal unit sites - an issue perhaps outside of MISO’s scope, but worth understanding before MISO moves forward. Prior to MISO taking action, we request further discussion on how these conversions may impact interconnection opportunities or raise other issues that will need to be addressed outside of the Attachment Y or MTEP processes. We look forward to that ongoing discussion.
Thank you again for moving these important issues forward and considering this feedback.
ITC Holdings thanks MISO for the opportunity to comment on the MTEP Selection of Non-Transmission Alternatives (PAC-2020-2) discussed at the PSC.
ITC appreciates the work MISO has done on its revisions to the BPM and the Submittal Form for NTA. The creation of a defined schedule and process for the submittal of these projects along with defined expectations for them will allow all involved to move forward with the same expectations for the process. ITC also appreciates MISO reaffirming that synchronous condensers will be Transmission Assets.
WPPI appreciates MISO’s posting of a MS WORD version of the proposed BPM revisions. We have added suggested red-line edits and comments to the posted BPM section, with a focus on improving clarity, and will submit that document in conjunction with this response.
The submission form included at the end of the presentation appears rough, but probably adequate for its purpose. We suggest that MISO remain open to refining the form as improvement ideas develop via experience with the process.