MISO Dashboard

There are multiple issues associated with the requirements for an Electric Storage Resource (ESR) to charge from the grid that require resolution and include, but are not necessarily limited to:

1. It is not clear from the language in BPM-012 whether firm, non-firm, short-term, or long-term Point-to-Point (PTP) transmission service is required.
a. At the May 2, 2023 IPWG meeting, MISO stated that long-term firm PTP transmission service is required, which is potentially in excess of the requirements of Order 841, which is limited to ensuring that applicable transmission charges are applied (reference 2a below).

2. It is not clear why Network Integration Transmission Service (NITS) would not satisfy the Order 841 requirement that the same transmission charges that apply to load should apply to storage resources when they are charging from the grid.
a. Per Order 841, paragraph 292, “When an electric storage resource is charging to resell energy at a later time, then its behavior is similar to other load-serving entities, and we find that applicable transmission charges should apply. However, it may be possible for different transmission charges to apply to load resources located at a single node (such as pumped-hydro resources) that are paying a nodal price for energy and load resources that are located across multiple nodes (such as load-serving entities) that are paying a zonal price for energy. Therefore, to the extent that load resources located at a single node pay different transmission charges than load resources located across multiple nodes, then storage resources that are located at a single pricing node, as long as, as discussed in the next paragraph, they are not being dispatched to provide an ancillary service by an RTO/ISO.”

3. It is not clear if the transmission service requirement(s) applies to ESRs connected to the distribution system.

4. The generation interconnection process for an ESR includes an analysis of charging at 100% in the shoulder case. This analysis should address the transmission system reliability concerns sited by MISO as the driver for requiring ESRs to procure long-term firm PTP service, rather than utilizing short-term firm or non-firm transmission service. It is not clear how the interconnection process integrates, if at all, with the TSR process.
a. If long-term firm transmission service is required, there appears no need (or value) to evaluation of the charging state in the interconnection process.

5. While the BPM language as written would allow an ESR to satisfy the obligation to procure transmission service through any PTP product, MISO’s indication at the IPWG that long-term firm PTP service is needed would not provide flexibility to obtain transmission service only during those times when the ESR is actually charging from the grid.
a. This flexibility would provide tremendous reliability value when compared to the risk of not obtaining long-term firm transmission service.

6. It is unclear how ESRs are exempt from transmission service requirements when charging from the grid to supply ancillary services. BPM-012 simply states that the OASIS reservation capacity is reduced and used in all charge calculations and that the reduction (ESR Exemption) is based upon “market data”.
a. How does this work, if for example, monthly firm transmission service is acquired and the ESR provides ancillary services for a period of less than a month? b. If ESRs absorb power (load) while providing ancillary services and do not require transmission service, how do we ensure that system constraints are respected?