By Michael Brooks
Acciona Wind Energy USA is accusing MISO of blocking it from selling power into PJM by improperly interpreting a process designed to streamline energy exports.
The U.S. arm of the Spanish energy conglomerate told the Federal Energy Regulatory Commission last week that MISO is excluding a portion of its 180-MW Tatanka wind farm’s capacity from participating in its pre-certified path study process (EL15-69). The FERC-approved process allows interconnection customers to avoid lengthier studies when MISO evaluates their transmission service requests (TSR).
LaCrosse-Madison 345 kV
As part of a generator interconnection agreement (GIA) with Montana-Dakota Utility, the South Dakota wind farm currently receives 36 MW of network resource interconnection service (NRIS) from MISO. It is scheduled to reach full NRIS deliverability at the beginning of 2019, when the 345-kV LaCrosse-Madison line in Wisconsin is scheduled to be completed.
MISO claims that a customer must have deliverable NRIS as of the date of the pre-certification study, which has a five-year planning horizon, for its TSR to be considered. That is not supported by any language in the RTO’s Tariff, Acciona said.
“MISO has read un-filed terms and conditions into the Tariff by excluding customers like Tatanka Wind from participation for a portion of their NRIS that will be obtained, pursuant to the GIA, within the five-year planning horizon,” the company said. “The result of reading in additional restrictions on the planning process is to delay by 18 months after the full 180 MW of NRIS is available to Tatanka Wind the benefit of the pre-certified path study process.”
Acciona also noted that PJM has determined that Tatanka already has a full 180 MW of deliverable transmission service in the form of network integration transmission service (NITS), 108 MW effective June 1 and an additional 72 MW effective in 2018.
Addressing Uncertainty
FERC approved the pre-screening process in 2011, saying it would address “uncertainty and delays resulting from its existing procedures for handling transmission service requests to the MISO border [that] may inhibit export transactions.”
It is one of a number of efforts the commission has made to improve the efficiency of transmission between MISO and its adjacent regions. (See Impatient FERC Hints at Action on PJM-MISO Seams Disputes.)
Transmission customers eligible for the pre-certified path study process may be granted TSRs over the path without the need for a system impact study (SIS).
MISO, however, granted Tatanka only 36 MW of service to PJM beginning in 2016 and delivered an SIS “estimating several hundred million dollars in upgrades” that would be required to grant the full TSR, ignoring the expected opening of the LaCrosse-Madison line, Acciona said.
‘Worthless Study’
“Tatanka Wind understands that transmission service must be provided in a manner that maintains the reliability of both transmission systems. This may justify the 18-month delay in applying the process in order to ensure sufficient time to study availability of transmission along the pre-certified paths. This does not, however, justify an 18-month delay based on ignoring NRIS that will take effect within the five-year planning window,” the complaint said. “MISO ignored the planned increase in NRIS, resulting in a worthless study identifying redundant upgrades no one believes are necessary to support the request for service following already planned upgrades.”
The company said MISO’s interpretation discriminates against exporters, because customers serving load within MISO are not subject to the 18-month delay.
Acciona requested that FERC order MISO to grant the TSR under fast-track procedures.
MISO has not yet responded to the complaint. In an April 3 email included as an exhibit to Acciona’s complaint, MISO Director of Interconnection & Planning Tim Aliff told the company that if it disagreed with MISO’s interpretation of its rules, it should pursue a change through the stakeholder process.
