During the February 1, 2023, Planning Subcommittee (PSC) meeting, participants heard a presentation on Flow Control Devices in Planning from Steve Leovy, WPPI. Stakeholders were invited to provide feedback on the presentation.
Please provide feedback by February 22.
Comments of the WATT Coalition in response to the February 1, 2023 presentation on Flow Control Devices in Planning from Steve Leovy, WPPI
February 22, 2022
The WATT Coalition is pleased to see MISO’s planning subcommittee considering applications of Advanced Power Flow Control (APFC). Incorporating APFC into MISO’s system planning and operations would improve grid capacity and flexibility, lowering congestion costs, reducing renewable energy curtailment, and increasing optionality in extreme conditions. In the longer term, deployments of Grid Enhancing Technologies (GETs) (APFC, dynamic line ratings and topology optimization) are necessary to increase transmission capacity rapidly and affordably in response to changes in the generating resource mix and growing electrification.
WATT is happy to offer MISO further resources for learning about Grid-Enhancing Technologies (GETs). Unlocking the Queue with Grid Enhancing Technologies, produced by the Brattle Group in 2021, modeled the cost and value of GETs across the Kansas and Oklahoma grids. The study found that twice as much renewable energy could interconnect if GETs were deployed widely, and that the cost of that deployment would be offset by production cost savings in less than a year. MISO's territory is similarly wind-rich, and we believe MISO should comprehensively evaluate how GETs could improve the transmission system for all customers.
Ultimately, APFC and other GETs should be included in all transmission planning and operations. We welcome an initial inclusion in the LRTP planning process as proposed by WPPI. We encourage MISO to work towards including these commercialized technologies in all of their transmission-related work, including grid operations and generator dispatch.
About the WATT Coalition
The Working for Advanced Transmission Technologies (WATT) Coalition is a trade association supporting wide deployment of GETs, to accelerate the clean energy transition and lower energy costs. Members include grid technology, renewable energy, and investment companies, and a transmission owner. WATT currently supports three technologies in particular: 1) Dynamic Line Ratings (DLR) which determine the true, real-time capacity of power lines. 2) Advanced Power Flow Control (APFC) which changes line impedance so planners and operators can fully utilize lines with available capacity. 3) Topology Optimization which identifies the best grid reconfigurations to reroute flow around bottlenecks. These three technologies reduce congestion costs and improve economic dispatch, situational awareness and reliability.
Invenergy appreciates the opportunity to provide feedback regarding WPPI’s proposal to the PSC on Flow Control Devices in Transmission Planning Processes.
Invenergy supports the inclusion of Grid Enhancing Technologies (GETs) in MISO’s transmission planning processes. GETs can maximize the existing grid capacity by making the grid a dynamic, dispatchable asset while new transmission is built. While GETs may not always be able to substitute the need for a new transmission line, the complementary benefits of these technologies will help optimize the scope and cost of transmission planning.
Invenergy encourages MISO to dedicate further time at the PSC to determine how best to incorporate GETs like Flow Control technology in the MTEP and LRTP processes.
Alliant Energy supports the concepts raised in WPPI’s presentation on flow control in transmission planning and believes further discussion should occur. In addition, MISO should directly engage with this work given the unique position MISO has regarding system knowledge, access to information and computing ability. There is a growing role for flow control solutions and MISO should support engagement with these solutions in order to unharness the value they can provide.
Flow control will not displace the need to focus on additional potential transmission build out. However, flow control solutions can help leverage the existing system and assist in maximizing the benefits from increased capability added to the system. Going forward, MISO needs to focus not only on system expansion but also on system optimization to help meet reliability, renewable energy, and affordability objectives in the future.
DTE appreciates the opportunity to provide feedback on the flow control in transmission planning studies discussion. We also appreciate Steve Leovy and WPPI Energy for bringing this topic to the awareness of MISO and its stakeholders. As it pertains to flow control devices and other grid enhancing technologies, we encourage MISO to be proactive in its evaluation of all traditional and non-traditional solutions that address the transmission system in a cost-efficient manner. The transmission system is expected to go through a substantial upgrade over the next several years with the construction of long-range transmission projects that are projected to cost ratepayers up to $100 billion dollars. By excluding flow control devices and other grid enhancing technologies from the transmission planning process we increase the risk of over-building while placing unnecessary cost burdens on customers. In order to stay in the spirit of the Commissions just and reasonable standard the most optimal transmission solutions should be sought, and the planning processes should be engineered and design as such to facilitate that endeavor. Additionally, the need for transmission planning that is more inclusive of new technologies was also emphasized by the Commission in their most recent Transmission Planning and Cost Allocation NOPR where they propose to require Transmission Providers to fully consider these options in their respective planning processes. We urge MISO to be proactive in their approach to this item as well as other topics that mirror the concept of leveraging existing facilities to help support grid reliability such as converting retired generators into synchronous condensers. With the unprecedent transmission spend that is included in the LRTP projects it is incumbent upon us to plan with the appropriate level of prudence so that we can ensure that we deliver value to customers.
The Missouri Joint Municipal Electric Utility Commission DBA The Missouri Electric Commission sees value in WPPI's proposal and is in favor of further discussion of this issue at the appropriate stakeholder forum(s).
AES Clean Energy appreciates the opportunity to provide feedback on WPPI’s presentation on Flow Control in Transmission Planning Studies. AES Clean Energy believes that Grid Enhancing Technologies- including Flow Control technologies such as HVDC lines, Series Capacitors, etc.- are important grid modernization tools that can address a wide range of issues. AES Clean Energy supports the wide adoption of GETs, and therefore opposes restricting their consideration for deployment to a single transmission planning process, such as Long-Range Transmission Planning (LRTP), as suggested by WPPI’s presentation. AES Clean Energy would encourage MISO and its stakeholders to consider the deployment of GETs- including dynamic line ratings and topology optimization in addition to flow control- as a possible solution to mitigate any number of constraints identified in any of MISO’s planning processes and generator interconnection studies.
AES Clean Energy disagrees with WPPI’s assertion that beneficial flow-control projects are “unlikely to emerge from Baseline Reliability Project or Market Efficiency Project” studies, and their presentation suggests that they are only appropriate to consider in LRTP. Flow control technologies can be quickly deployed to address economic congestion and quickly offset deployment costs. This efficiency means that GETs are a beneficial technology that could be appropriate to mitigate congestion identified in Market Efficiency Project Study and MISO should not limit their consideration to a single transmission planning process.
MISO should broaden this initiative to consider with its stakeholders the types of use cases and constraints that each type of Grid Enhancing Technology could mitigate and modify the relevant tariff and BPM language to give transmission owners and interconnection customers the flexibility to identify the best fit, least cost solution to mitigating constraints beyond the suite of solutions employed today. FERC has already indicated support for the wider consideration and deployment of Grid Enhancing Technologies in their Long-Range Transmission Planning NOPR and their Interconnection Reform NOPR. MISO should continue its trend of being forward looking on innovating its transmission and interconnection processes by working with its stakeholders to determine how it could consider a wider deployment of GETs beyond the LRTP projects suggested by WPPI.
ENVIRONMENTAL SECTOR WRITTEN COMMENTS ON WPPI’S 2/1/23 PRESENTATION RE: FLOW CONTROL IN TRANSMISSION PLANNING STUDIES
The Environmental Sector appreciates WPPI’s presentation concerning the benefits of evaluating flow control devices in transmission planning studies and urges other stakeholders to present similar opportunities for MISO and the Transmission Owners to increase the efficiency of the MISO transmission grid.
Flow controls are proven technology that increase the efficiency of transmission grid operations. The Environmental Sector supports the installation of grid-enhancing technologies (GETs)--like flow controls--that will increase the efficiency of the grid and help drive down costs for consumers.
We do not know whether the Long-Range Transmission Planning (LRTP) process is the appropriate venue for evaluating flow controls and other GETs or if they are more appropriately evaluated in the near-term planning processes such as the annual MTEP and DPP studies, or if flow controls should be evaluated in both LRTP and the near-term planning processes. Regardless, we agree with WPPI that MISO should be evaluating the installation of flow control devices on the MISO grid. The Department of Energy published a report, Advanced Transmission Technologies in December 2020, which includes information on Power Flow Controls (PFCs). https://www.energy.gov/sites/prod/files/2021/02/f82/Advanced%20Transmission%20Technologies%20Report%20-%20final%20as%20of%2012.3%20-%20FOR%20PUBLIC.pdf
The Environmental Sector also urges the regulators within MISO states to consider requiring their transmission owners to install GETs in the near-term when appropriate, even when not required by MISO. For example, we understand that MISO will not model the installation of advanced conductors unless the transmission owner has already agreed in advance to use those conductors, which have a much higher capacity and improve resilience.
In conclusion, GETs such as flow control devices and advanced conductors are proven technologies that increase efficiency and drive down consumer costs, but remain significantly underutilized on the MISO system. Given that no MISO utility has yet to embrace these technologies and realize their benefits, the responsibility for getting them onto the MISO system lies with MISO itself and state regulators.