In the April 26, 2023, meeting of the Planning Advisory Committee (PAC), MISO presented proposed changes to BPM-020 as part of the improvements to Attachment Y. Stakeholders were invited to submit feedback.
Comments are due by May 10.
Environmental Sector Comments on Attachment Y Changes
May 10th, 2023
The Environmental Sector appreciates the opportunity to provide comments to the PSC on Attachment Y changes. While we remain neutral on MISO’s effort to tighten requirements for retiring units, the effect of this change will be more SSR designated units, creating a greater sense of urgency for the transparency reforms the Environmental and other MISO Sectors have been requesting for years. A lack of transparency around Attachment Y retirements has led to significantly higher costs to load than would otherwise naturally occur. Generator replacements can readily step in, eliminating costly SSR payments, if provided the opportunity. The problem is that notice of opportunity is not provided. By the time notification of retirement and SSR designation is given to MISO stakeholders, it is too late to initiate the Generation Replacement process. Furthermore, in nearly all cases, public notice of the retirement was provided years in advance, rendering the confidentiality clause and missed opportunity for Generator Replacement needless.
To address this issue, MISO can work from two angles –Attachment Y changes, and Generator Replacement changes. While Generator Replacement changes are out of scope for these comments (though we strongly encourage MISO to separately take them up), Attachment Y process changes to transparency are within scope, and particularly timely in light of the direction provided by FERC Commissioner Clements on the subject. Following a detailed discussion of transparency concerns expressed by Industrial Customers (the same concerns expressed by the Environmental Sector), Clements states “I encourage MISO and its stakeholders to revisit whether more timely publicnotice of forthcoming suspensions and retirements is feasible.” (Docket No. ER23-630, Clements’ Concurrence, page 2). The Environmental Sector agrees that MISO’s markets and planning processes will work only as well as “the information available to market participants and other stakeholders.” As generator retirements and the need to replace those generators increases due to the tighter requirements planned for implementation by MISO in June 2023, increased transparency becomes even more urgent. MISO can avoid multiple unfavorable situations and unnecessary costs that are certain to occur in the future with the proposed changes, by today initiating today a stakeholder discussion to improve transparency related to generator retirements and the Att. Y process, and/or implementing changes to remove barriers in the Generator Replacement process.
The current process is reactive when the speed of the energy transition requires that we be proactive. Confidentiality concerns alone should not foreclose the opportunity for stakeholders to develop a creative solution that would allow for a proactive generator replacement process while respecting such confidentiality when it is needed. Greater transparency does not mean that all information must be completely public–only that there is a transparent process by which generation developers may learn of planned retirements ahead of time so that they may work with owners of the retiring plant to come up with generation replacement solutions. One such idea–although at this moment we reserve our opinion on it–would be a confidential clearing house where developers could learn of planned retirements in order to proactively work with interconnection rights holders to come to a voluntary arrangement that is beneficial for all parties while meeting MISO’s reliability needs.
We look forward to working with MISO and other stakeholders to further explore how we can turn planned retirements into an opportunity that will help ensure a more reliable grid while embracing the energy transition that is currently taking place.
MPSC Staff generally supports the direction of the BPM 20 changes but is interested in MISO’s reasoning behind the proposed thresholds beyond alignment with NERC TPL standards.
The proposal on establishing a study group in section 6 of BPM20 is a good proposal. However, the presentation does not indicate the term study group as a defined term.
BPM20 section 5 uses the term called AD Hoc Study Group , which is defined in Section 5.5 and is only used in Section 5 of the BPM.
MISO should define the Section 6 Study Group in Section 6. However, if MISO feels the Section 6 Study Group follows the principles of the Ad Hoc Study Group of Section 5 then MISO should move the section 5.5 definition of Ad Hoc Group to a global term for all of BPM20. Then the Section 6 Study Group can be called an Ad Hoc Study Group.
Otherwise, MISO should make a new definition.