In the August 16, 2022 meeting of the Planning Subcommittee (PSC), stakeholders were invited to submit feedback on MTEP Selection of Non-Transmission Alternatives (PAC-2020-2) including the following questions:
Comments are due by September 9, 2022.
DTE appreciates the opportunity to provide feedback to MISO related to the MTEP selection of Non-Transmission Alternatives (NTA) including the option to convert a retired generator into a synchronous condenser. DTE especially applauds MISO’s efforts to continue exploring ways in which Non-Transmission owners specifically, can repurpose their retired generators as synchronous condensers. Working with the stakeholder community in creating the administrative pathway in which these opportunities can be analyzed on a comparable basis, regardless of the asset classification, will help facilitate the transmission of energy in both a reliable and cost-effective manner. To further the dialogue on the selection of Non-Transmission Alternatives including the option to convert a retired generator into a synchronous condenser MISO has requested feedback on the following questions:
In response to the focus areas, DTE would like to see MISO leverage components of existing processes for the communication for voltage needs as well as market products. The current practice of Generator Operators managing the voltage support according to the voltage thresholds set by the Transmission Operator is an option that could be easily adopted with the conversion of a retired generator to an SCU. Additionally, the compensation for reactive power can follow a similar cost-based approach that is outline in Schedule 2 of the tariff for System Support Resources. As it relates to the technical characteristics of the equipment, we support MISO’s decision to offer stakeholders more information through a presentation on the technical aspects. Then last, as it relate to the final focus area, excluding Non-Transmission owners from leveraging the option to convert their retired generators to an SCU directly contradicts FERC Order 1000 which states the Transmission Providers obligation to give “comparable consideration” to non-transmission alternatives.
Pertaining to question two, DTE recommends that MISO take more ownership in the exploration of Non-Transmission alternatives and provide Stakeholders with the resources they need to conduct a thorough evaluation of the alternatives. The process to explore and identify potential Non-Transmission alternatives should be a collective exercise between MISO and the Stakeholder community. Currently the onus is placed on Stakeholders to inform MISO of their desire to pursue Non-Transmission Alternatives based on an analysis conducted by MISO and Transmission Owners. The analysis is often shared with Stakeholders much later in the process after conclusions have already been drawn from the evaluation. Stakeholders would appreciate MISO taking more of a lead role in ensuring that the NTA selection process is free of any bias towards traditional transmission solutions, by creating an inclusive and transparent process that allows Stakeholders to offer input through all stages of the analysis.
As it relates to question three, DTE recommends that MISO leverage existing processes included in section 4.3.1.2.2.1 of BPM 20 related to Non-Transmission Alternatives. To the extent the that the conversion of a retired generator to an SCU conceptually replicates a planned generator interconnection based NTA, the current NTA process should be applied.
In reference to question four, again the existing practice of the Generator Operator maintaining voltage needs within the thresholds set by the Transmission Operator can be employed for the SCU. Specifically, before the conversion of the Generator to the SCU, the Generator Operator would normally operate the automatic voltage regulator (AVR) of the generator in AUTO and any changes to its state would be reported to the Transmission Operator within 30 minutes of the change occurring. Also, the Generator Operator would operate the reactive output of the unit such that the Transmission Operator provided voltage target and upper/lower limits are respected as per the NERC Standard VAR-001-5. In this regard, the Generator Operator had a day-to-day responsibility to raise and lower the AVR setpoint as needed to maintain the local BES bus voltage within given limits; this operation was carried out independently of the BA or TO Control Center involvement. After the conversion, the Generator Operator would remain in control of the Unit’s AVR as described above. This would ensure continued compliance with the NERC Standard VAR-001-5. In addition, as the SCU AVR setpoint is raised/lowered, this action would be performed in tandem with other Generator AVRs in the region under the Generator Operator control, thus ensuring that the dynamic reactive power injection or consumption is purposefully coordinated so that the local BES bus and overall system target voltage objective is achieved.
To summarize, many of the questions posed can be addressed with existing processes included in MISO’s Business Practice Manuals with opportunities for enhancements to the NTA framework. Specific to the enhancements, identification and exploration of Non-Transmission Alternatives should be a collaborative exercise between MISO and all relevant stakeholders. Given the Transmission Providers key position within the electrical system we recommend that 1) MISO take lead in seeking out NTA opportunities, 2) engage Stakeholders much earlier in the NTA evaluation process, and 3) Adopt flexible policies that allow non-vertically integrated utilities convert retired generators into synchronous condensers.
DTE appreciates the opportunity to provide feedback to MISO related to the MTEP selection of Non-Transmission Alternatives (NTA) including the option to convert a retired generator into a synchronous condenser. DTE especially applauds MISO’s efforts to continue exploring ways in which Non-Transmission owners specifically, can repurpose their retired generators as synchronous condensers. Working with the stakeholder community in creating the administrative pathway in which these opportunities can be analyzed on a comparable basis, regardless of the asset classification, will help facilitate the transmission of energy in both a reliable and cost-effective manner. To further the dialogue on the selection of Non-Transmission Alternatives including the option to convert a retired generator into a synchronous condenser MISO has requested feedback on the following questions:
In response to the focus areas, DTE would like to see MISO leverage components of existing processes for the communication for voltage needs as well as market products. The current practice of Generator Operators managing the voltage support according to the voltage thresholds set by the Transmission Operator is an option that could be easily adopted with the conversion of a retired generator to an SCU. Additionally, the compensation for reactive power can follow a similar cost-based approach that is outline in Schedule 2 of the tariff for System Support Resources. As it relates to the technical characteristics of the equipment, we support MISO’s decision to offer stakeholders more information through a presentation on the technical aspects. Then last, as it relate to the final focus area, excluding Non-Transmission owners from leveraging the option to convert their retired generators to an SCU directly contradicts FERC Order 1000 which states the Transmission Providers obligation to give “comparable consideration” to non-transmission alternatives.
Pertaining to question two, DTE recommends that MISO take more ownership in the exploration of Non-Transmission alternatives and provide Stakeholders with the resources they need to conduct a thorough evaluation of the alternatives. The process to explore and identify potential Non-Transmission alternatives should be a collective exercise between MISO and the Stakeholder community. Currently the onus is placed on Stakeholders to inform MISO of their desire to pursue Non-Transmission Alternatives based on an analysis conducted by MISO and Transmission Owners. The analysis is often shared with Stakeholders much later in the process after conclusions have already been drawn from the evaluation. Stakeholders would appreciate MISO taking more of a lead role in ensuring that the NTA selection process is free of any bias towards traditional transmission solutions, by creating an inclusive and transparent process that allows Stakeholders to offer input through all stages of the analysis.
As it relates to question three, DTE recommends that MISO leverage existing processes included in section 4.3.1.2.2.1 of BPM 20 related to Non-Transmission Alternatives. To the extent the that the conversion of a retired generator to an SCU conceptually replicates a planned generator interconnection based NTA, the current NTA process should be applied.
In reference to question four, again the existing practice of the Generator Operator maintaining voltage needs within the thresholds set by the Transmission Operator can be employed for the SCU. Specifically, before the conversion of the Generator to the SCU, the Generator Operator would normally operate the automatic voltage regulator (AVR) of the generator in AUTO and any changes to its state would be reported to the Transmission Operator within 30 minutes of the change occurring. Also, the Generator Operator would operate the reactive output of the unit such that the Transmission Operator provided voltage target and upper/lower limits are respected as per the NERC Standard VAR-001-5. In this regard, the Generator Operator had a day-to-day responsibility to raise and lower the AVR setpoint as needed to maintain the local BES bus voltage within given limits; this operation was carried out independently of the BA or TO Control Center involvement. After the conversion, the Generator Operator would remain in control of the Unit’s AVR as described above. This would ensure continued compliance with the NERC Standard VAR-001-5. In addition, as the SCU AVR setpoint is raised/lowered, this action would be performed in tandem with other Generator AVRs in the region under the Generator Operator control, thus ensuring that the dynamic reactive power injection or consumption is purposefully coordinated so that the local BES bus and overall system target voltage objective is achieved.
To summarize, many of the questions posed can be addressed with existing processes included in MISO’s Business Practice Manuals with opportunities for enhancements to the NTA framework. Specific to the enhancements, identification and exploration of Non-Transmission Alternatives should be a collaborative exercise between MISO and all relevant stakeholders. Given the Transmission Providers key position within the electrical system we recommend that 1) MISO take lead in seeking out NTA opportunities, 2) engage Stakeholders much earlier in the NTA evaluation process, and 3) Adopt flexible policies that allow non-vertically integrated utilities convert retired generators into synchronous condensers.
Transmission Owners Sector Feedback on MTEP Selection of Non-Transmission Alternatives
At the August 16 meeting of the Planning Subcommittee, MISO requested feedback on MTEP Selection of Non-Transmission Alternatives, Including the following questions:
The Transmission Owners Sector offers the following inpput on these questions:
Are there focus areas missing from slide 4 to provide “comparable consideration” to the use of retired generators as synchronous condensers?
What opportunities exist for MISO to be more proactive in its identification and what additional information is needed to help educate or inform opportunities for Non-Transmission Alternatives?
What consideration might be needed regarding operating instructions?
The Environmental Section submits the following response to MISO’s requested feedback on four specific questions. Our feedback on each question is presented in turn below:
Are there focus areas missing from slide 3 to provide “comparable consideration” to the use of retired generators as synchronous condensers?
As another “focus area,” we believe that MISO should consider how new rules and processes related to converting retired generators to synchronous condensers would relate to rules regarding new-build (not based on retired generators) synchronous condensers. This would not only avoid creating unintended problems for new-build synchronous condensers, but it may also help aid in their deployment. See also our response to question 2, below.
What opportunities exist for MISO to be more proactive in its identification and what additional information is needed to help educate or inform opportunities for Non-Transmission Alternatives?
The environmental sector supports the inclusion of synchronous condensers (SC’s) in their planning analysis, but the current scope of inclusion of these resources at retiring generators is too limited. Maintaining spinning mass is important at retired generation sites, but this is not the only opportunity for deploying SC’s. As it was indicated in MISO’s RIIA study, these resources will be necessary to maintain grid stability in the shift to variable resources in the future, and this shift is indeed happening at a swift pace in MISO. To remedy this limited scope of only looking at retiring generators, the Environmental Sector proposes that MISO at least integrate SC’s into MTEP models to provide a full understanding of the scope of benefits.
Furthermore, we believe that MISO should be taking a holistic, all-approaches view to resolving grid stability issues, and as such should look at more than just retired generator sites for SC’s, as well as the use of other grid stabilization technologies. As MISO stated in its 10/12/2021 Planning Subcommittee Meeting:
RIIA shows that as renewable penetration increases and conventional generation declines, dynamic stability issues become increasingly challenging to solve. Depending on location and severity, these issues can be solved by either tuning inverter-controls or by deploying technologies equipped with dynamic support capabilities such as SCUs, VSC-HVDC, SVCs, STATCOMs, or grid-forming inverters. The resource mix will drive the role, size, location, and mix of these solutions. Therefore, a holistic view of the projected system needs is required to find the most effective combination of solutions.
[PSC Item 05b MTEP Selection of Non-Transmission Alternatives (IR092), slide 13]
Additionally we encourage MISO to extend NTA consideration and inclusion to other GETs and non-NTA solutions such as reconductoring existing lines with advanced conductor technology that have higher ratings and additional resilience benefits.
What additional questions exist to inform how the use of retired generators as synchronous condensers impact the interconnection process?
The Environmental Sector has no comments responsive to this question at this time.
What consideration might be needed regarding operating instructions?
The Environmental Sector has no comments responsive to this question at this time.
Alliant Energy supports the comments submitted by DTE. Also, regarding opportunities for MISO to be more proactive with non-transmission alternatives (NTAs), it would be helpful for MISO to perform more of its own analysis to help show the viability (or lack thereof) of NTAs as well as non-traditional transmission alternatives and provide this information and analysis for stakeholders to review. For example, solutions such as flow control technologies could be helpful to manage flows on the system in certain situations; MISO and stakeholder should work together with stakeholders to understand these opportunities. NTAs and non-traditional transmission alternatives should also be explored in terms of how they could be deployed to extract more value/capability out of the existing system as well as proposed upgrades.
In the August 16, 2022 meeting of the Planning Subcommittee (PSC), stakeholders were invited to submit feedback on MTEP Selection of Non-Transmission Alternatives (PAC-2020-2) including the following questions:
WPPI sees no obvious missing focus areas.
WPPI notes that MISO need not rely on other parties to propose generator conversion to synchronous-condenser operation, but can propose this alternative itself, subject to Attachment Y confidentiality restrictions. MISO can also raise this possibility with Attachment Y submitters. We recommend both these steps.
WPPI notes that synchronous condensers provide not only static voltage support, but also inertia, dynamic voltage support and active swing-damping capability. MISO should account for these capabilities to the extent relevant in MISO’s studies.