[Federal Register Volume 85, Number 74 (Thursday, April 16, 2020)]
[Notices]
[Pages 21223-21226]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-08021]
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DEPARTMENT OF ENERGY
Federal Energy Regulatory Commission
[Docket No. ER20-588-000]
Midcontinent Independent System Operator, Inc.; Notice of
Technical Conference
By order dated March 10, 2020,\1\ the Commission directed staff to
convene a technical conference regarding Midcontinent Independent
System Operator, Inc.'s (MISO) filing of proposed revisions to its Open
Access Transmission, Energy and Operating Reserve Markets Tariff to
allow for the
[[Page 21224]]
selection of a storage facility as a transmission-only asset (SATOA) in
the MISO Transmission Expansion Plan (MTEP). The technical conference
will explore issues including, but not limited to, MISO's proposed
evaluation and selection criteria for SATOAs, the SATOA's market
activities and any potential wholesale market impacts of those
activities, how MISO's current formula rate structure accommodates cost
recovery for SATOAs, a SATOA's potential effects on the generator
interconnection queue, and operating guides that will apply to a
SATOA.\2\
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\1\ Midcontinent Indep. Sys. Operator, Inc., 170 FERC ] 61,186
(2020).
\2\ Id. P 56.
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Take notice that the Commission will hold this staff-led technical
conference on Monday, May 4, 2020, between 9:00 a.m. and 5:00 p.m.
(Eastern Time). This conference will be held remotely, as further
described below.
Participants should be prepared to discuss, at minimum, the
following:
A. Evaluation and Selection Criteria for SATOAs
MISO proposes Tariff language stating that, to be selected for
inclusion in Appendix A of the MTEP as a transmission asset, a proposed
SATOA must demonstrate:
a. Unique characteristics or circumstances of the proposed SATOA
necessary to meet the identified Transmission System performance
requirements and not otherwise available at comparable costs from other
proposed solutions, including speed of operation, lead-time to
implement, right-of-way, or other property considerations.
b. A need to resolve the Transmission Issue(s) through the storage
facility's functioning as a SATOA instead of as a Resource that
participates in [MISO's] markets.\3\
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\3\ MISO Dec. 12 Filing, Tab A, proposed MISO Tariff Att. FF,
Sec. II.G.1.c.i (71.0.0).
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MISO states that an example of a unique characteristic is the
storage asset's ability to rapidly inject and withdraw real or reactive
power in solving transmission issues that could not otherwise be
resolved if the storage asset was participating in markets.\4\
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\4\ MISO Dec. 12 Filing, Transmittal Letter at 2 n.5.
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1. What is an ``identified Transmission System performance
requirement?'' How and where are they identified? What is the
difference between an identified Transmission System performance
requirement and a Transmission Issue? What are examples of Transmission
System performance requirements that can be addressed by a proposed
SATOA?
2. What criteria will MISO consider when determining whether a
proposed SATOA has unique characteristics or circumstances necessary to
meet the identified transmission system performance requirements? How
does MISO intend to communicate these criteria to stakeholders and
participants in the MTEP? What does MISO mean by ``other property
considerations''?
3. What criteria will MISO consider when determining whether there
is a need for the storage facility to solve the transmission issue
through the storage facility's functioning as a SATOA instead of as a
resource that participates in MISO's markets? How does MISO intend to
communicate these criteria to stakeholders and participants in the
MTEP?
4. With regard to MISO's example of a unique characteristic-i.e., a
storage asset's ability to rapidly inject and withdraw real or reactive
power in solving transmission issues-how can storage as transmission be
distinguished from storage resources participating in markets that
could have their dispatch schedules adjusted to rapidly inject or
withdraw real or reactive power to solve transmission issues if needed
as part of the normal security constrained dispatch of market
resources?
5. If a traditional transmission project and a SATOA can both meet
a transmission system performance requirement equally well, how will
MISO determine which solution to select in the regional transmission
planning process? If multiple SATOA proposals have unique
characteristics or circumstances necessary to meet the identified
transmission system performance requirements, how will MISO determine
which solution to select in the regional transmission planning process?
6. If the entity that proposes a SATOA does not provide sufficient
information for MISO to determine whether the SATOA meets the criteria
outlined in the Tariff excerpted above, how will MISO proceed? For
instance, will MISO attempt to determine if the SATOA meets the
criteria using MISO's own independent analysis? Will that analysis be
available to other participants in the regional transmission planning
process?
7. How will MISO's evaluation criteria ensure that SATOAs are
limited to only those electric storage resources that are performing a
transmission-specific function?
8. Please explain how MISO will communicate its decision in
approving a SATOA. For instance, MISO stated in its filing that there
is currently a storage resource pending as a recommended project in
MTEP19. Is the explanation provided in the MTEP19 executive summary
regarding this recommended project representative of the type of
explanation that MISO intends to provide in the future? What steps will
MISO take if additional information is requested from participants in
the regional transmission planning process?
MISO states that comparative evaluations of a proposed SATOA will
include the minimum and maximum capacity required to address the
transmission issue to ensure that excess storage capacity is not
treated as a transmission asset. MISO further states that cost recovery
under transmission rates is limited to the cost of the maximum capacity
to be determined needed to address the transmission issue.\5\
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\5\ MISO Dec. 12 Filing, Tab A, proposed MISO Tariff Att. FF,
Sec. II.G.1.a.ii (71.0.0).
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9. How will MISO determine the maximum capacity needed to address
the transmission issue? Please explain.
B. SATOA Market Activities and Market Impacts
MISO states that the SATOA owner is responsible for maintaining the
necessary state of charge to be ready to serve the transmission
function for which it was approved in the MTEP, and MISO will exercise
functional control of the SATOA for transmission purposes only, i.e.,
charging and discharging to meet the transmission need will be done at
the direction of MISO.\6\
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\6\ MISO Dec. 12 Filing, Transmittal Letter at 6-7; MISO Answer
at 15.
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10. What does it mean for a SATOA to be under MISO's ``functional
control,'' while making the SATOA owner responsible for maintaining
state of charge? Will MISO tell the SATOA when to charge and discharge
while the SATOA is performing to meet the transmission need? What is
the practical difference, if any, between charging/discharging to
``meet'' the transmission need and charging/discharging to be ``ready
to serve'' the transmission need?
11. How will MISO ensure that a SATOA under its ``functional
control'' is available (e.g., not fully charged when needed to withdraw
power and not fully discharged when needed to inject power) to solve a
transmission issue?
12. Please explain your view on whether and, if so, how the
charging/discharging activities of the SATOA directed under MISO's
functional control or, in connection with the SATOA owner's
responsibility to maintain state of charge, impact the wholesale energy
and capacity markets. For example, would these activities impact
transmission capacity, congestion, and/or other resources'
[[Page 21225]]
ability to meet energy and ancillary services needs, etc.? Please
explain.
MISO proposes that the SATOA owner will need a registered market
participant to receive energy net costs when charging and discharging
under MISO's functional control. MISO states that the market
participant for a SATOA will be credited the applicable Real-Time Ex
Post LMP for Non-Excessive Energy and will be charged for Non-Excessive
Energy withdrawals. MISO explains that the SATOA market participant
then must provide the net revenues back to the transmission owner, and
those net revenues will offset the transmission revenue requirement
associated with the resource.\7\ MISO states that the SATOA will be a
price taker.
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\7\ MISO Dec. 12 Filing, Transmittal Letter at 23, Tab A,
proposed MISO Tariff, Module C, Sec. 40.3.3.3.a.i (44.0.0).
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13. Does a SATOA's direct participation in the wholesale energy
markets as a price-taker create potential impacts on the wholesale
energy and capacity markets by, for instance, displacing otherwise
marginal or infra-marginal resources and possibly changing the energy
market price? Why or why not? If energy market impacts occur, will they
be minimal or might they be mitigated, and if so how?
14. Please provide further information on: (1) What types of entity
could serve as the SATOA's market participant; (2) whether such market
participant and/or the SATOA owner would have market-based rate
authority; and (3) if the market participant were affiliated merchant
function staff, how the standards of conduct would be met.
C. Cost Recovery for SATOAs
MISO proposes that costs resulting from a SATOA's market activities
directed under MISO's functional control be collected through
transmission rates in a manner consistent with the treatment of costs
associated with the transmission project type in which the SATOA is
included in Appendix A to the MTEP. Any revenues collected from the
SATOA's market activities directed under MISO's functional control
would be credited through transmission rates in a manner consistent
with the treatment of costs associated with the transmission project
category in transmission rates.\8\
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\8\ MISO Dec. 12 Filing, Transmittal Letter at 22, Tab A,
proposed MISO Tariff, Att. FF Sec. II.G.6 (71.0.0).
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15. How does MISO's current formula rate structure in Attachments
O, GG, or MM accommodate cost recovery for SATOAs? Are any of those
provisions sufficient to allow net market revenue to be credited
through the transmission revenue requirement? Will the net energy
revenue be credited outside the existing formulas, e.g., through a
separate rider?
16. If the existing formulas will need to be modified to
accommodate SATOAs, what types of modifications are needed and when
will such modifications be filed to ensure that they are effective
before a SATOA becomes operational?
D. Impact on the Generator Interconnection Queue
MISO proposes that, if it or a stakeholder identifies a potential
impact to newly-interconnecting generation resources in the
interconnection study process, MISO will assess whether the proposed
SATOA will have an impact. If the assessment demonstrates that the
necessary operating mode of the proposed SATOA will cause the need for
additional system mitigation, the cost of such mitigation will be
included in the evaluation of the proposed SATOA as compared with other
potential transmission solutions. MISO proposes that its impact
assessment may include targeted contingency analyses applying NERC TPL
and applicable regional and local planning criteria to evaluate the
incremental impact.\9\
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\9\ MISO Dec. 12 Filing, Transmittal Letter at 20-21, Tab A,
proposed MISO Tariff Att. FF, Sec. II.G.1.d (71.0.0).
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17. Please provide further details on how MISO would assess the
impact of a proposed SATOA on newly-interconnecting generation
resources and compute costs if system mitigation is needed. Would MISO
account for changes due to restudies in the interconnection study
process and, if so, how? Could a SATOA be considered a contingent
facility? Will MISO's interconnection procedures be modified to include
any of these details? Does MISO intend to include any of these details
in its Business Practice Manuals? Will the analysis of the impact of
the proposed SATOA on the newly-interconnecting generation resources be
available to market participants in the regional transmission planning
process and/or interconnection customers in the interconnection queue?
18. Will MISO's assessment of impacts include assessment of delays
in the interconnection queue, and if so, how would MISO mitigate those
delays? If not, why is it not necessary to assess potential delays to
the interconnection queue as a result of a proposed SATOA?
19. MISO states that the cost of additional mitigation if the SATOA
affecting newly-interconnecting generation resource is selected as the
preferred transmission solution in the MTEP will be included in the
evaluation of the proposed SATOA. Will such costs also be included in
the total SATOA cost recovered through transmission rates and, if so,
how?
E. Operating Guides
MISO states that it will coordinate with the SATOA owner, MISO
Operations, and the transmission operator to develop an operating guide
that will establish (1) conditions for which the SATOA should be
discharged and charged to meet the anticipated planning objective and
(2) boundaries for operation that will be consistent with this
objective and will reflect the unique operating parameters of the
individual SATOA.\10\
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\10\ MISO Dec. 12 Filing, Transmittal Letter at 21, proposed
MISO Tariff, Att. FF, Sec. II.G.2 (71.0.0).
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20. Please provide a summary and explanation of the information
that may be contained in the operating guides. Please provide specific
examples of the information to be contained in the operating guides.
F. Miscellaneous
21. Are there any scenarios where a SATOA might be called upon
under emergency conditions to relieve an issue outside of the specific
transmission issue for which the SATOA was selected? If so, how will
MISO handle any out-of-market payments that the SATOA receives?
22. Are SATOAs studied for reliability impacts in the same way as
storage as non-transmission alternatives, particularly regarding
dynamic stability? If not, why not? Please explain in detail how SATOAs
will be studied for reliability impact.
The technical conference will be led by Commission staff, and is
open to the public. All people interested in participating in the
conference must register at the following link: https://www.ferc.gov/whats-new/registration/05-04-20-form.asp by no later than noon on May
1, 2020. There is no registration fee. Information on joining the
technical conference will be posted on the Events Calendar available at
https://www.ferc.gov/EventCalendar/EventsList.aspx?View=listview.
The conference will include discussions between Commission staff
and MISO. If time permits, there may be an opportunity for parties that
are participating in the conference to ask questions or provide
comments. The proposed agenda for the technical conference is described
below. Procedures to be followed at the
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conference and any changes to the proposed agenda will be announced by
staff at the opening of the conference. The technical conference will
not be transcribed.
Commission conferences are accessible under section 508 of the
Rehabilitation Act of 1973. For accessibility accommodations, please
send an email to [email protected] or call toll free 1-866-208-
3372 (voice) or 202-502 -8659 (TTY); or send a fax to 202-208-2106 with
the required accommodations.
Following the technical conference, the Commission will consider
post-technical conference comments submitted on or before May 25, 2020.
The written comments will be included in the formal record of the
proceeding, which, together with the record developed to date, will
form the basis for further Commission action.
For more information about this technical conference, please
contact Mark Byrd, 202-502-8071, [email protected]. For information
related to logistics, please contact Sarah McKinley, 202-502-8368,
[email protected].
Dated: April 10, 2020.
Nathaniel J. Davis, Sr.,
Deputy Secretary.
Storage as a Transmission-Only Asset (SATOA) in MISO Technical
Conference--Webex Teleconference
Monday, May 4, 2020, 9:00 a.m.-5:00 p.m.
9:00 a.m.-10:30 a.m. Evaluation and Selection Criteria for SATOA
Identified Transmission System performance requirement
Unique Characteristics or Circumstances
Functioning as SATOA Compared to Market Participant
10:30 a.m.-10:45 a.m. Break
10:45 a.m.-11:30 a.m. Evaluation and Selection Criteria for SATOA
(continued)
Traditional Transmission Project compared to SATOA
SATOA Evaluation Criteria
Communication of Decision Approving a SATOA
11:30 a.m.-12:45 p.m. SATOA Market Activities and Market Impacts
Meaning of ``Functional Control''
Impact of SATOA Activity on Wholesale Market
Information Regarding Market Participant
12:45 p.m.-1:30 p.m. Lunch
1:30 p.m.-2:15 p.m. Cost Recovery for SATOAs
Formula Rate Structure
2:15 p.m.-3:30 p.m. Impact on the Generator Interconnection Queue
Assessing the Impact of a SATOA on Newly Interconnecting
Generating Resources
Assessment of Delays and Mitigation
3:30 p.m.-3:45 p.m. Break
3:45 p.m.-4:15 p.m. Operating Guides
Information in Operating Guides
4:15 p.m.-5:00 p.m. Miscellaneous
Emergency Conditions
Reliability Impacts
[FR Doc. 2020-08021 Filed 4-15-20; 8:45 am]
BILLING CODE 6717-01-P