PSC: Market Participation and Registration of Co-Located Load and Generation (behind the same POI) (PAC-2024-4)_NextEra (2024724)

Advanced Energy United appreciates the opportunity to submit these comments in response to the Midcontinent Independent System Operator, Inc.’s (MISO) request for stakeholder feedback on Market Participation and Registration of Co-Located Load and Generation (behind the same POI) (PAC-2024-4), following the July 24, 2024, Planning Subcommittee meeting.

Advanced Energy United is a national association of businesses making the energy we use secure, clean, and affordable. Advanced Energy United is the only industry association in the United States that represents the full range of advanced energy technologies and services, both grid-scale and distributed. Advanced energy includes energy efficiency, demand response, energy storage, wind, solar, hydro, nuclear, electric vehicles, and more. The comments expressed in this submission represent the position of Advanced Energy United but may not represent the views of any particular member. 

• What mechanisms are there to include load in generation study process and tie to a specific generator and storage project without creating restudies?
  • Currently generation and load studies don’t take one another into account, resulting in either the load or generator being subject to network upgrades without knowing the upgrade costs of the other. Each is studied independently, load via MTEP and the respective TO, and generation via the queue. This can create de-coupled and potentially overestimated upgrade costs for each resource. Studying load and generation together in a harmonized interconnection process could expedite results and reduce upgrades that may not be necessary There currently is no market model to support the balance that exists where load is brought to generation locations.
• How can the system best incent new large loads to design projects that have lowest impact to other ratepayers?
  • Concurrent load and generation studies would create much needed economic efficiencies and improve system reliability by providing a holistic view of the system. This could lower overall study costs and infrastructure investment thereby contributing to lower costs for consumers. A market construct/model should be created that reflects the efficiencies that co-located projects bring to the grid, such as aligning the timing and costs of resource study requests in one interconnection process, as well as build registration processes for standard, behind-the-meter, and demand response registration and settlements.
• What mechanisms exist or could be created to address injection or withdrawals to the system if the load or resource do not perform/behave as intended or modeled in the study process?
  • Proposal provisions could include GIA injection/withdrawal level and shape conditioned on the general load/generation ramp and schedule being conditional on load being constructed, establishing contractual limits and consequences of violating that agreement. This approach may provide more flexibility for the interconnecting customer to develop solutions for situations where the load does not develop as expected as compared to making any GIA conditional upon load sitting.
• How could or should “co-location” be defined (single point of interconnection, zonally, other?)
  • New load and generation sited in the same zone should have the option, but not the obligation, to be studied as co-located and potentially be reviewed through separate study processes than stand-alone generation and load interconnection requests.   

Advanced Energy United appreciates the opportunity to provide these comments and looks forward to continuing to work with MISO to explore options to facilitate demand response participation in these markets. Please reach out to Lisa Barrett with any questions.

Respectfully submitted,

Lisa Barrett

202.380.1950 x3177

lbarrett@advancedenergyunited.org

WEC Energy Group supports a comprehensive discussion of the Co-located Generation and Load topic at both the technical level (Planning Subcommittee - PSC and the Interconnection Process Working Group - IPWG) and at the policy level (Planning Advisory Committee - PAC).  At the technical level, the PSC and IPWG need to design study procedures that align generation interconnection and load interconnection with a recognition that the capacity factor of the generation may not exactly match the load factor of the load.  Any misalignment of the two capacity factors will result in energy injection into or withdrawal from the Bulk Electric System (BES) that requires full analysis to determine the need for interconnection and network upgrades, including the need for transmission service when the load exceeds the output of the co-located generation.  The study procedures (and related generation interconnection service and transmission service agreements) should accommodate relay and control schemes that limit the net withdrawal or injection into the BES from the co-located load and generation, 

At the policy level, WEC Energy Group is concerned with footnote #1 on slide #8 of NextEra’s July 24, 2024 presentation to the PSC.  That footnote references the need for a Load Serving Entity (LSE - i.e. a Muni, Co-op, or IOU) to “sleeve” the energy behind the single Point of Interconnection meter between the co-located generation and load.  The PAC should evaluate whether MISO’s tariff can define and require an LSE to “sleeve” power between two third parties.  We suspect that the MISO tariff cannot dictate such an agreement, which calls into question the viability of a non-LSE co-locating a generator with load.  We further believe that state law pertaining to public utilities could limit the ability or requirement of an LSE to “sleeve” energy.

Duke appreciates the opportunity to provide our overall comments below on Nextera’s July 24^th presentation.

Slide 8 of Nextera’s presentation shows a wind resource contractually connected to load, but when the wind is not blowing (in other examples, generation of any kind disconnects for some reason), then the full load is imported from the grid. To keep ratepayers from being negatively impacted and not pay for costs caused by co-located load use of grid services when not self-generating or load does not show up, MISO would need to determine system upgrades required by studying what the impacts of full load or maximum generation could have if this arrangement were to import/export from/to the grid.

The problem Nextera raises could be solved with a quicker queue process that only takes one year. Then, the timing for load interconnection and generator interconnection would be more aligned. There does not appear to be a huge opportunity for physically co-located generation and load with any limits (which should be a requirement to keep ratepayers from being negatively impacted by a transaction like this) on drawing/pushing from/to the grid. 

If MISO defines co-located load more broadly (zonally) and adds the appropriate protections/studies that would allow utilities with an obligation to serve load to qualify for this faster process to get new generation on-line.

Apex Clean Energy appreciates the opportunity to provide its feedback on the NextEra proposal for studying co-located generation and load together.

PSC: Market Participation and Registration of Co-Located Load and Generation (behind the same POI) (PAC-2024-4)_NextEra (2024724)

Apex believes that this issue is important and will become more important in the coming years. Large loads are increasingly looking to co-locate with reliable, clean energy generation facilities. Apex supports the NextEra proposal that generation and co-located load be studied together.

The over-arching issue is that the load and generation should be studied together and “netted” against one another. This will result in the lowest impact to ratepayers.

The governing documents can be drafted, and electrical protection systems can be engineered such that the system impacts are known and can be appropriately studied.

Apex believes that “co-location” should typically be defined as behind a single point of interconnection.

Thank you for considering our feedback. We appreciate MISO's efforts in continuously improving the interconnection process and look forward to seeing positive changes implemented.

Apex Clean Energy

In response to the stakeholder presentation made at the July 24 PSC, the MISO Transmission Owners (Owners) have the following comments.

The Owners recognize this proposal for a combined load and generation interconnection process tying together specific resources raises a number of higher-level policy questions. Among these questions are the applicability of Schedule 9 and 26 rates to these large load customers; the appropriateness of creating a parallel generator interconnection process to the DPP queue; what rights generators that use a process of this type would have in MISO’s energy markets; and how to ensure such a process is connected to existing study processes so an “end run” around those existing processes would not be created. The Owners acknowledge efforts are already under way to improve the generator interconnection queue timelines and the EPR process frequently used for load interconnections. The Owners recommend the policy issues are addressed first before attempting to work on detailed process solutions.

Specifically, the Owners have concerns that this proposal places MISO in a position to evaluate retail access rules which are governed by state-level policies which are clearly outside of MISO’s scope.  Most states in which MISO members are located have defined retail load service territories; this contradicts the high-level assumption in this proposal that the generator could sell power directly to the load without the involvement of the LSE.  Slide 8 in the July 24, 2024 stakeholder presentation states a LSE could buy the energy from the generator under a PPA and then “sleeve the energy behind the meter to the load”, but if the local LSE does not purchase the energy this arrangement would not fit into state retail designs. This highlights one of the contractual complexities with this proposal. 

Additionally, the Owners have concerns regarding contractual and operational limits needed for both the load and the generator. The grid needs to operate safely and reliably.  First, without enforceable limits or curtailments which could guarantee the co-located load demand and generation output are always equal, a full system impact study and accompanying set of upgrades would be needed for the full generation injection when the load is not present, and to fully serve the load with the generation is not available. Second, synchronizing the timing of in-servicing and commissioning both the generator and the load would present challenges, and there is the issue of limits needed when the generator comes online without the load or load comes without the generator.

The current generator interconnection process is designed to connect generation for use in the wholesale market and not under retail services. Load interconnections are analyzed under the MTEP and TSR study processes.  It should also be noted that load interconnections are generally evaluated under more stringent NERC planning criteria such as N-1-1 or P6 contingency events, which the generator interconnection process generally does not evaluate.

If the generation is less than the minimum load, adding generation and load at the same POI could simplify matters tremendously.  It could simply be treated as a load, avoiding the generation queue entirely.  The generation would look like negative load and simply lower the amount of load at the POI.  Reverse power relays could ensure the no generation is delivered to the transmission system.  The transmission impacts (and studies) would be much less than installing separate load and generation interconnections at different POIs.

The forecasted growth in both customer load and generator interconnections suggests that process changes and adaptations must be on the table. However, there are many policy questions that must be addressed before creating an entirely new process out of whole cloth. It is unclear whether an entirely new interconnection process is needed, as suggested in the presentation, or if success can be achieved through adaptations to existing interconnection processes.  It is also unclear what the end product looks like.  Does the generator achieve ERIS/NRIS or something else?  Does the load achieve NITS or something else?  The Owners note there is a FERC technical conference pertaining to this topic scheduled for November 1, 2024. Given the challenges articulated above, the Owners suggest these, and other policy questions need to be addressed and answered before evaluating the appropriate path forward. 

The OMS Transmission Planning Work Group (TPWG) provides this feedback to MISO on NextEra’s study proposal for co-located generation and load. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.

The TPWG supports exploring NextEra’s study proposal of co-located generation and load. The TPWG believes that improvements to the interconnection of load and supply co-located behind the meter can be identified that would facilitate efficient siting of new renewable generation and load without having to wait and pay for expensive and potentially unnecessary network upgrades. However, it is essential that any proposed enhancements or novel processes that arise from this study do not adversely affect the reliability of the bulk electric system.

The TPWG is concerned that contractual limits alone between the co-located entities may not ensure the reliable operation of the bulk electric system. Under such a contractual supply or ownership arrangement, MISO and TOs would still need to evaluate the existing transmission system in the vicinity of the interconnection point to determine what, if any, additional net flows could reliably occur (i.e., output from the generator to the transmission system or supply from the system to serve the new load). Clear and enforceable operational, contractual, and physical restrictions would be needed to prevent either the generation or load from exceeding allowable net flow limitations. The TPWG believes that financial penalties alone would be insufficient to safeguard reliability and system safety given the likely scale of these projects.  

The TPWG recognizes this discussion may implicate certain rules and policies regarding franchise service territories but offers no comment on whether these sales should be allowed (from generation directly to load). Such decisions should be addressed by each respective state or local legislature and regulatory commission with jurisdiction over retail sales.