In the March 3, 2022, meeting of the Reliability Subcommittee (RSC), stakeholders were invited to review and submit feedback on Proposed BPM-008 changes for Section 4.3 Coordination of Generation Outages.
Please provide feedback by March 18, 2022.
WPPI has no concerns with the proposed edits to BPM-008 Outage Operations, section 4.3 Coordination of Generation Outages. However, we offer the following additional feedback re MISO’s generator outage approval process:
(1.) It’s not clear to us that in the case of an outage that is not timely submitted, MISO has the leeway to respond “as soon as practical” (vs. within 3 months when timing of outage submittal accommodates). See the MISO tariff, Module C, Section 38.2.5.iii.
(2.) The proposed edits only have MISO performing a reliability analysis 6 months prior to the start of an outage if it was submitted timely. Wouldn’t MISO want to perform such an analysis in the case of any outage if the timing of the outage submittal accommodates?
(3.) We would appreciate further discussion of the timing of MISO’s approval of outages that are not timely submitted. In the case of such an outage, within what timeframe does MISO usually complete its generator outage analysis (BPM-008, section 4.4)? That is, typically, what is the timeframe for “as soon as practicable” (BPM-008, section 4.3)? It seems reasonable to expect MISO to approve or deny an outage not timely submitted based on the results of the maintenance margin at the time the outage was submitted and MISO’s initial generator outage analysis. We recognize that grid conditions may change and the outage may need to be re-scheduled to maintain reliability. However, unless MISO has approved (accepted) the outage not timely submitted, the Generation Resource is not eligible to be compensated for the cost of rescheduling.
(4.) “If a Generator Planned Outage has been rescheduled, the Transmission Provider shall issue a report to a stakeholder group, after the date that the originally scheduled outage has passed.” (MISO tariff, Module C, section 38.2.5.g.iv) To which stakeholder group is this information being provided? At a high-level (perhaps on an annual basis), how many Generator Planned Outages have been rescheduled and what was the cost?
MEMORANDUM
TO: MISO RELIABILITY SUBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: COORDIANTION OF GENERATION OUTAGES PROCESS REVIEW
DATE: MARCH 18, 2022
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the March 3, 2022, Reliability Subcommittee (RSC) meeting concerning MISO’s proposed changes to the coordination of generation outages process and the related BPM-008 Section 4.3 redlines.
The EOC’s think that MISO providing a response to an outage request in the two weeks to three-month time frame after the request is submitted, while not final, would be very helpful and aid in the planning process. This would allow the generator owner and MISO to work together well in advance of an outage to address potential issues.
The above process in conjunction with the reliability analysis six months prior to the start date of the outage should allow for most outages to be approved at this point. If not, this still leaves some time to address any issues that might hold up this approval. Waiting as late as 2 days prior to the beginning of an outage to receive final approval does not allow sufficient time to make other plans or develop other solutions if approval is not received, and this practice should not be continued. If the generator has followed all the prescribed steps and rules, its outage should be approved at the six-month reliability review. The EOC’s understand that past this six-month mark, that unexpected issues and system changes may occur. If so, the current practice of asking a generator to move its outage and keeping it whole via attachment BB should continue.
MISO should update current tools to perform the above evaluations and not just rely on maintenance margin. The outage que priority should be transparent and be something a generator owner can make use of when planning an outage.
Regarding the need for updated tools, MISO should further explore and provide clarity as to whether the outage study process improvements contemplated in the July 29, 2021, presentation MISO made at the Reliability Subcommittee are a part of this new proposed process. MISO should also provide additional details around the study results verbiage associated with each phase of the process (Approved, Pre-Approved, Study, etc.).
The EOCs look forward to working with MISO to improve the outage coordination process and appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.