During the May 3, 2023, Planning Subcommittee (PSC) meeting, MISO discussed revised BPM language, the updated Non-Transmission Alternative submission form and proposal to close this issue after review at the Planning Advisory Committee. MISO is requesting Stakeholder feedback on the items presented.
Please provide feedback by May 24.
MISO Transmission Owners Feedback on “Non-Transmission Alternative submission form and proposal to close this issue after review at the Planning Advisory Committee
May 24, 2023
During the May 3, 2023, Planning Subcommittee (PSC) meeting, MISO discussed revised BPM-020 Section 4.3.1.2 language, an updated Non-Transmission Alternative submission form and proposed to close this issue, which was also tied to considerations of retiring generators converting to synchronous condensers after final review by the Planning Advisory Committee.
MISO requested Stakeholder feedback on the items presented, and in response, the Transmission Owners (Owners or TOs), provide the comments below.
Proposed BPM-020 Revisions
Given that MISO has moved towards a more formalized process for considering alternatives to projects submitted by Transmission Owners in annual MTEP cycles, the Owners suggest that the current and proposed process-related provisions in Section 4.3.1.2.2.1, “Contracted Demand Response or Planned Generator Interconnections” either be moved to a stand-alone section on Process, within Section 4.3.1.2, “Development of Alternative Solutions to Projected Issues”, or be incorporated directly within that Section.
It appears that Section 4.3.1.2 “Development of Alternative Solutions to Projected Issues” may also require revision, as it includes the following:
With regard to non-transmission alternatives, in order to ensure comparability for such non-transmission alternatives, Attachment FF requires adherence to the following:
• For generation alternatives, a Generation Interconnection Agreement must be executed pursuant to Attachment X of the Tariff and in accordance with the requirements of Attachment FF.
• For demand response alternatives, a demand response agreement must be executed between the applicable LSE(s) and end-use customer(s) in accordance with the requirements of Attachment FF.
Similarly, the current version of 4.3.1.2.2.1, “Contracted Demand Response or Planned Generator Interconnections”, includes factors considered for “deferring, de-scoping, and/or withdrawing a previously proposed transmission project” which would also generally apply to any alternative, and therefore should likely be moved to or incorporated in Section 4.3.1.2 more generally or in a new section dedicated to these considerations.
The Owners also note that the current version of Section 4.3.1.2.2.1, “Contracted Demand Response or Planned Generator Interconnections” describes the process by which projects are determined by MIOS to be eligible for alternative solutions, stating:
“Prior to presenting identified issues to stakeholders at an SPM, MISO will confer with the Transmission Owners to determine which projects have drivers or other constraints that cannot be adequately or feasibly addressed by non-transmission alternatives, and will then flag these projects as not compatible with non-transmission alternatives.”
The Owners have observed that this process is not consistently followed by MISO, as Owners are not consistently provided the opportunity to review MISO’s determinations prior to the information being posted with SPM 1 materials. This can lead to requests for information relating to potential alternatives to projects that are not eligible for an alternative solution and creating inefficiencies for all parties. Therefore, the Owners request that this review be included in the graphical timeline representation requested above.
Regarding the Alternative Submission Form
MISO Planning Modeling Manual v4.1 Clean105063.pdf (misoenergy.org)
This can be accomplished by adding a footnote, with links above to the third line item on the form regarding Model on Demand submissions.
Regarding MISO’s Proposal to Close PAC-2020-2, MTEP Selection of Non-Transmission Alternatives
The Owners support MISO’s proposal to close this issue after final review of the Planning Advisory Committee.
The Owners appreciate MISO’s efforts to clarify the process for consideration of alternatives to transmission solutions, and encourage MISO to take this opportunity to provide as much clarity regarding this process as possible in considering related revisions to BPM-020.
DTE appreciates the opportunity to provide feedback on the MTEP Selection of Non-Transmission Alternatives. We are disappointed in MISO’s decision to limit Synchronous Condenser Units (SCU) as transmission assets and subsequently closing out the issue. As the system operator in the region, it is MISO’s responsibility to ensure that the grid is functioning in a manner that delivers affordable energy to its customers reliably. Given how diverse the stakeholders are within MISO, the range of viable solutions to address transmission needs are not limited to transmission solutions only. FERC acknowledges as much by requiring public utility transmission providers to consider Non-Transmission Alternatives (NTA) on a comparable basis. The notion behind FERC’s rulemaking was to avoid sub-optimal outcomes by relying solely on transmission solutions. MISO is in a unique position as an Independent System Operator (ISO) to establish policy that helps facilitate an unbiased evaluation of NTAs. MISO has recognized (and continues to recognize) the reliability attributes of generating assets without stipulations that they be considered transmission assets. Converting a generating unit into a SCU requires minor modifications to the asset allowing it to perform at least part of the same function that it provided prior to its conversion. There is opportunity for MISO to work directly with stakeholders in developing service agreements that commit generating owners to providing the reliability support needed from SCUs. MISO’s refusal to enter into such agreements due to them being unique circumstances not only conflicts with the Commission’s standards around comparability, but also conflicts with MISO’s mission to ensure the right amount of electricity is delivered in the most reliable, affordable, and sustainable way possible.
Equally important is the timeline that stakeholders have to conduct a thorough analysis of the MTEP projects to provide transmission and/or non-transmission alternatives upon receiving MISO's MTEP models. The currently deadline to submit alternatives is May 31st of each planning year, regardless on the timing that MISO publishes and shares its modeling data with stakeholders. When MISO is behind schedule in publishing its models, as it has been for the past two years, it condenses the timeline that stakeholders have to evaluate alternatives. Stakeholders should be afforded a minimum of 6-8 weeks after the MTEP models have been shared to develop alternatives. Additionally, MISO should validate the projects 4 weeks in advance of the deadline for alternative submission in order to give stakeholders enough time to provide input.
We strongly urge MISO to reconsider its decision to limit Synchronous Condensers to transmission assets and to provide stakeholders ample time to evaluate NTAs once models have been published.