RSC: DRAFT Congestion Cost Reconfiguration Process Document (20220623)

National Grid Renewables recognizes that MISO is facing significant and rising congestion within its northern footprint and appreciates the recognition of this issue. National Grid Renewables offers the following comments on the current proposal for managing economic re-configuration requests.

At a high level, National Grid Renewables notes several broad concerns with economic re-configuration and its cascading effects on other processes below.

• Many areas of congestion need to be addressed by the long-term planning process, including MTEP and LRTP. MISO should ensure that there are adequate guardrails to prevent these underlying issues from being masked from the long-term planning or interconnection processes. This coordination should include a regular review of current re-configurations being used to address congestion and/or top areas of significant recurring congestion, for consideration in MTEP and LRTP.
• National Grid Renewables requests that MISO provides more detail on how economic re-configurations will be communicated to and used by staff in the long-term planning process. It is unclear exactly what that coordination might look like. MISO should provide stakeholders with a presentation or information outlining how staff will reflect approved economic re-configurations into the planning or interconnection studies.
• National Grid Renewables strongly objects to the removal of “impact on other market participants” as an evaluation criterion and encourages MISO to re-include this in the proposal.
• MISO is in a better position to impartially assess the merits of re-configuration proposals. In MISO’s current proposal, both MISO and the TO independently assess the impacts of each re-configuration. It would be more appropriate for MISO to be the sole assessor of each re-configuration to avoid bias or inequitable treatment.
• MISO should make the studies of each re-configuration proposal study public and available for review. Especially given the removal of “impact on other market participants” as an evaluation criterion, market participants need an opportunity to raise concerns with or appeal each study. The suggested timeline of 10 days from submission to approval would not be adequate for such review and would need to be extended to accommodate a review period. National Grid Renewables suggests that an adequate review period would be 15 business days, in addition to the current 10-day review period, so a total of 25 business days from start to finish.    

Additionally, National Grid Renewables offers the following comments on the specific provisions of the proposal below.

• National Grid Renewables supports MISO’s suggestion to curate a list of the top 10 constraints each month, or something similar. This information is highly valuable to stakeholders.
• Under a 5% relief threshold, National Grid Renewables has concerns over the volume of re-configurations that would need to be studied. Based on feedback at the RSC, this threshold was set based on a current anecdotal proposal(s) and may not be appropriate in all scenarios. National Grid Renewables would support different thresholds for different line capacities, e.g., 20% for a 69kV line, 15% for a 115/138/161kV line, and 5% for a 345kV line.
• MISO should ensure that the TO criteria for an “acceptable” vs “unacceptable” reliability risk threshold is consistent between all re-configuration proposals and represents a reasonable level of risk tolerance for all parties. National Grid Renewables understands that this risk level will be different between different Transmission Owners, but the threshold should remain consistent between re-configuration requests.
• MISO should include specific language for how often these reconfigurations must be periodically evaluated for remaining “effective or reliable”.
• MISO should clarify if there will be a time limit to the re-configurations. MISO expressed that these re-configurations have an intended duration of anywhere up to aprx 3 years, but there should be consideration given around how to handle or exclude a significantly longer re-configuration request, or a request that is repeated or “renewed”.

National Grid Renewables thanks MISO for their attention to this issue and re-emphasizes the importance of coordination with long-term and interconnection planning.

Entergy Operating Company Feedback on DRAFT Congestion Cost Reconfiguration Process Document presented at the June 23, 2022 Reliability Subcommittee Meeting

July 8, 2022

The following feedback on the DRAFT Congestion Cost Reconfiguration Process Document presented at the June 23 meeting of the Reliability Subcommittee (RSC) is offered by the Entergy Operating Companies (Entergy)[1], as requested by MISO.

In addition to the general comments below, Entergy has submitted comments in the redlined version of the document posted with the RSC meeting materials, by email. 

Generally, these comments suggest:

• areas where more details should be included to avoid confusion in the implementation of the proposed process. 
• inclusion of a “References” section, and
• inclusion of the Transmission Owner (TO) in the review of proposed reconfigurations, in particular, to address instances when the TO and TOP do not align; in which case, the TO would have an interest in evaluating the risk to assets or any impacts on planned work in the area.  In MISO, there are many TOs who are not TOPs and their input is needed to protect their interests and their assets, which could be impacted.

Duke Energy appreciates the opportunity to provide comments on this DRAFT Congestion Cost Reconfiguration Process Document.  Assessing and reassessing the system at the suggestion of random submitters who do not pay a fee for their dart toss poses a significant drain on a TOP’s resources.  We would recommend a “pay to play” philosophy to limit the requests only to the serious participants to help avoid issues currently being experienced in the generator queue and to compensate the TOP for their “above and beyond” normal work efforts.  Our remaining comments are listed below. 

Document Language under “Phase 2: Evaluation” in the Risk identification section: Determine if a single ended line trip will adversely impact the objective of the reconfiguration by introducing the potential for N-1 overloads. The TOP and RC can either accept this risk or mitigate it. 

Duke comment: Does the TOP also pay for the mitigation in addition to accepting the risk of moving from ‘normal’ operations to ‘reconfigured’ operations of the system?

Document Language under “Phase 2: Evaluation:” The result of each reliability assessment by each GOP or TOP shall be either “acceptable” or “unacceptable” reliability risk.

Duke comment: Language does not permit a TOP to opt out: a TOP result shall be either “acceptable” or “unacceptable” reliability risk.   Is an acceptable answer “TOP didn’t study it” without assessing a risk as unacceptable? 

Document Language under “Phase 2: Evaluation:” Upon an “unacceptable” reliability assessment by any one TOP or MISO, the request is immediately returned to the submitter. In such case, the organization deeming the request as posing an unacceptable reliability risk shall provide details about the results of the evaluation to justify the decision.

Duke comment: Who receives details about “unacceptable” assessment?  That information is likely to be Non-public Transmission Information, containing critical infrastructure information or OASIS details.  TOP should not need to provide details and reasons why regarding an “unacceptable” assessment back to the submitter only to MISO as third-party check to avoid Non-Public Transmission Information being passed to market participants.  MISO would then be able to give generic decline answer without details to submitter.

Please see the attached document for feedback from Alliant Energy, Avangrid Renewables, EDF Renewables, Madison Gas & Electric, NewGrid Inc., NextEra Energy Resources, Orsted Onshore, and WPPI Energy.

DC Energy supports MISO and stakeholder discussion to explore reliable and economic reconfiguration options that result in a more efficient MISO dispatch. We believe the result of this effort will have both reliability and market efficiency outcomes and all interested stakeholders should have the opportunity to engage in this discussion. To that end we suggest that this effort be discussed, in addition to the the Reliability Subcommittee, at the Market Subcommittee as well. On the substance of the process, DC Energy recommends that transparency be a key element of this process. To that end we suggest that all stakeholders with CEII clearance be informed of potential changes at every step of the final process. As delineated in the draft process, after the initial screening MISO should communicate with the impacted TOPs, GOPs and other stakeholders with CEII clearance of the potential for MISO and TOP action. After the evaluation the same group of stakeholders should be informed if it results are ‘acceptable’.  DC Energy agrees with the ‘Implementation’ discussion in the draft process document with one addition. DC Energy suggests prior to implementation all stakeholders be notified of the impending change with 2 weeks notice. Similarly in the ‘exit’ phase stakeholders should be informed with 2 weeks notice.