During the November 11, 2022, meeting of the West Technical Study Task Force (WTSTF)stakeholders were invited to submit feedback on the possible alternative mitigations for the Lakefront 9 Support Supply Resource (SSR).
Please provide feedback by November 18.
The Environmental Sector appreciates the opportunity to provide feedback to MISO on possible alternative mitigations for the Lakefront 9 SSR. While we hope that solutions can be implemented that will shorten the timeline for SSR designation for Lakefront 9, the Environmental Sector’s primary focus in these comments is on procedural changes that will minimize or eliminate the need for future SSRs.
The Lakefront 9 SSR:
MISO has specified that an SSR designation will be required unless feasible solutions to thermal and voltage issues can be identified prior to the requested suspension date of February 1, 2023. The only mitigation measures MISO identified were the transmission upgrades below, none of which are expected to be in service prior to that date:
two 69-KV lines with ISD of 4/3/23 and 6/1/24; and
one new substation with ISD of 12/31/2027 (together “System Upgrades”)
The Environmental Sector would like to know if MISO conducted the following analyses relative to its conclusion that Lakefront 9 designation as SSR is warranted:
1) What would be the cost of accelerating the in-service dates of the identified System Upgrades when compared against the SSR payments for each year the SSR is likely to be in place, i.e. through 2027?
2) While MISO identified no known generation resources in the area that are capable of addressing the thermal and voltage issues, what alternative technologies did MISO consider, beyond the two new lines and one substation, to mitigate the need for this SSR? For example:
a) What would be the cost and benefits of installing energy storage at the site (as it will have multiple additional ancillary services and other benefits to the system) when compared against SSR payments plus the costs of those System Upgrades still needed?
b) What would be the cost and benefits of changing the unit from a generator to a synchronous condenser when compared against SSR payments plus the costs of those System Upgrades still needed for thermal violations?
Opportunities to Minimize or Eliminate Future SSRs
SSRs are simply a stopgap measure that is very expensive for load. Rather than throwing money away on a costly stopgap measure, MISO should move as quickly as possible to identify and facilitate viable, cost-effective, permanent solutions. The questions posed above for Lakefront 9 are the type of analysis that we hope MISO would conduct in the future.
Given timing limitations, it will be difficult for parties who are unaware of an upcoming Attachment Y filing to evaluate and propose alternatives to the owner of the retiring generator in time to avoid an SSR designation. (We appreciate MISO providing the timelines and deadlines that would be applicable to such a proposal, which can be found here: https://cdn.misoenergy.org/PSC%20Improvements%20to%20Attachment%20Y%20Retirement%20Process%20in%20BPM%2020%20Response%20(PAC-2022-1)%20(20221011)627023.pdf.)
We urge MISO to consider whether any additional adjustments could be made to the relevant timelines and deadlines of the Attachment Y and Generator Replacement processes that would facilitate third parties proposing innovative solutions to the generator owners in time to avoid an SSR designation. Specifically, we ask that MISO consider in SSR situations removing the requirement to submit a generator replacement request 1 year in advance of retirement along with removing the one-year advance requirement for change of ownership. Although generator replacement solutions could be proposed after the initial SSR designation because SSRs are evaluated on an annual basis, avoiding even a year of SSR payments should be the goal.
MISO has been discussing in many stakeholder venues the wisdom of repurposing retiring units on their sites to assist in addressing the needs that are emerging in this time of transition. Adjusting timelines or deadlines could not only further this goal but help to drive down consumer costs by avoiding SSRs and by attracting additional private capital into the MISO footprint through partnerships with the generator owners.