By Amanda Durish Cook
MISO on Thursday released the final scope of studies it will conduct through mid-2016 to help the RTO’s 13 states evaluate their compliance options under the Environmental Protection Agency’s Clean Power Plan.
The near-term analysis, expected to be completed by January, will look at the implications of various compliance paths. It will be based on the models used in prior analyses of the draft CPP with updates reflecting the final rule.
The mid-term analysis, expected to run through June, will use new models based on the most relevant compliance paths from the near-term study to determine likely resource buildouts and their locations under three separate futures. It will be the foundation for transmission development under the 2017 MISO Transmission Expansion Plan.
A long-term analysis, which will run through late 2018, will seek to develop transmission overlays needed to implement state compliance plans.
“MISO’s CPP study efforts over the next two [to] three years will create a bridge between the uncertainty and complexity that exists today and the modeling certainty needed for effective transmission overlay design,” the RTO wrote in its 10-page study scope.
The near-term study will model six scenarios, including a business-as-usual case, compliance via coal retirements and increased gas generation, and one weighted toward energy efficiency with a wind and solar buildout. The study will apply seven mass- and rate-based compliance options, both with and without interstate trading.
Preliminary Results in December
Bakke said MISO’s research team will have preliminary near-term analysis results ready to be presented at December’s Planning Advisory Committee meeting. “We’re trying to frontline as much as we can of this study into January and February,” said Jordan Bakke, senior policy studies engineer at MISO.
At last week’s PAC meeting, stakeholders expressed concern that the study could lead to an overwhelming output of information.
“We’re not going to lead with a mountain of data. We’re going to lead with the peak of the mountain,” Bakke responded.
MISO’s analysis, Bakke said, will examine the CPP from a system perspective, purposefully omitting an individual state breakdown. Bakke also called a study on reliability impacts under the rule “premature.” Instead MISO is asking for states to reach out with their plans so the RTO can begin applying them.
“When we move into our mid-term analysis, that’s when we get more detailed. For now, these are generic assumptions,” Bakke said. He added that the mix of rate-based and mass-based compliance in the study scope will be more nuanced when states come forward with their plans.
MISO isn’t putting itself under a deadline to qualify for the CPP’s Clean Energy Incentive Program, which rewards states with emission rate credits for “early action.” MISO said the program is “complex and will be further reviewed as the study progresses.”
States that delay coming forward with a plan or extension request beyond late 2016 will have a preset federal plan imposed on them in November 2017. State requests for extensions are due next September. (See Revised Clean Power Plan Allows More Time, Sets Higher Targets.)
“In the final rule, they’re really allowing states to do a wide variety of things… You have a fair bit of options in what your plan will look like,” said Mary Waight, one of MISO’s policy studies engineers, during a CPP informational workshop on Nov. 6.