Informal Feedback (202301)

Joint comments by the Environmental Sector and Alliant Energy regarding the proposed BPM-015 Sect. 6.1.1.1

At the November 29, 2022 PAC meeting, MISO proposed further revisions to BPM-015 Section 6.1.1.1 in an attempt to clarify what it intended in its previous proposed use of “like for like.” While we appreciate MISO’s responsiveness to overwhelming stakeholder opposition to the “like for like” requirement, we believe that MISO’s resolution sidesteps the substantive reasoning behind such broad stakeholder disagreement, instead offering replacement language that will likely have the same impact had MISO kept the “like for like” language in place. 

As indicated in the revised BPM language, MISO indicates that it must apply such a stringent standard in order “to avoid a full model build and restudy that would be required by including the MVP Portfolio.”  We understand this reasoning, but we reiterate our request to MISO to more fully consider how it can apply more flexibility into this process—such as by applying engineering judgment—to determine whether an MVP Portfolio project will mitigate the need for identified Network Upgrades. While we also appreciate the need for clear language in the BPM, we also believe—as do many stakeholders—that MISO has the expertise necessary to apply such engineering judgment or other methods that incorporate flexibility.

We understand that the cost of conducting necessary studies while keeping DPP cycles on track could be considerable, but we ask MISO to weigh this against the cost of redundant and duplicative buildout or Network Upgrades that would otherwise also be alleviated by MVP Portfolio projects.

In this regard, and considering that the most recently approved MVP Portfolio, LRTP Tranche 1, is already well underway, we ask the following: 

1. That MISO revisit its proposed BPM-015 Sect. 6.1.1.1 changes with respect to future MVP Portfolios, starting with LRTP Tranche 2.
2. That MISO provides information regarding any attempts it has made, or is making, to adopt a flexible framework, including any feedback from MISO’s legal department.
3. That MISO provide a more detailed response to the substantive aspects of stakeholder feedback submitted as part of the PAC feedback request, BPM-015 Updates for LRTP integration in GI (20221019),^[1] with respect to comments regarding MISO’s original like-for-like language and MISO’s resulting proposed BPM adjustment.

We appreciate your consideration of these comments and look forward to your response.

This is late feedback on an item due 1/6: 

PAC: Dispatch of Storage in MTEP and DPP Studies (20221129)01/06/2023

MISO’s proposal—to differentiate between storage interconnections that plan to charge from the grid vs those that do not—seems reasonable at first glance.  However, WPPI notes that assuming implicit charging for hybrid-interconnected storage (not needing to be modeled explicitly) may not make sense if the non-storage hybrid-resource component is simultaneously assumed to be injecting power into the system.  This appears to merit further thought.

We also note that MISO’s posted Planning Modeling Manual (https://cdn.misoenergy.org//MISO%20Planning%20Modeling%20Manual%20v4.1%20Clean105063.pdf) describes the summer shoulder scenario as follows:

• The Summer Shoulder shall represent a typical summer day peak value, not the shoulder values of a peak day.

We would expect storage resources to typically operate on a diurnal schedule, discharging during the peak hours each day (and, in any case, not charging during those hours). It may be that MISO nonetheless believes that these cases are appropriate to use to represent non-daily-peak hours; if so, we would suggest that this be described explicitly.

This is late feedback on an item due 1/6:

PAC: ERIS DFAX Reduction BPM-015 Proposed Language (PAC-2022-3) (20221129)01/06/2023

WPPI has seen significant increases in congestion that we attribute in part to new generation interconnections not accompanied by upgrades sufficient to ameliorate the congestion impact.  We were comfortable with Xcel’s proposal, as a means of better addressing this problem.  MISO proposes to exclude 345 kV and above facilities. We did not see the need to exclude higher-voltage facilities and would prefer that they not be excluded, but we do support the changes MISO proposes as a step in the right direction.

Item 6F – BPM-015 Updates for LRTP Integration in GI

NextEra Energy supports MISO’s proposal for incorporation of Long Range Transmission Plan (LRTP) facilities in the Generation Interconnection (GI) study cycle process. Allowing past GI study cycle projects to retroactively utilize LRTP upgrades would have negative and unpredictable impacts for existing resources on the MISO system and also for the projects in the current interconnection study queue.

It will also incentivize customers to stall during various stages of the study process to capture potential LRTP benefits that are, in many cases, 8-10+ years from operation and create additional logjams and significant uncertainty in the interconnection study queue.