MISO says it will have an easier time than expected complying with EPA’s Cross State Air Pollution Rule (CSAPR) because the final regulations are less stringent than the draft rule.
MISO Policy Studies Lead Jordan Bakke said a lot of the compliance conclusions that were made in MISO’s first study on the CSAPR have become “less relevant.” (See “MISO Releases EPA Air Pollution Rule Study and CPP Paper,” MISO Planning Advisory Committee Briefs.)
“From our reading of it, I think we can say we’re okay. There are other rules out there that are bigger changes,” Bakke told the Reliability Subcommittee.
The long-delayed CSAPR is aimed at reducing power plant emissions that contribute to ozone and fine particle pollution that is transported across state lines. Finalized in 2011, it was overturned by an appellate court in 2012 and restored by the Supreme Court in 2014. EPA says the rule, which takes effect in May, will reduce summertime emissions of nitrogen oxides from power plants in 23 states.
Of the 11 MISO states affected by the rule, Bakke said, Iowa and Arkansas now have the toughest road to compliance as their NOx budgets were tightened. MISO’s analysis also found that Michigan and Indiana now have more stringent seasonal NOx targets.
The RTO is sticking to its initial assessment that its states’ 2017 seasonal NOx budgets can be met through redispatch, although regional NOx emission trading is expected to be needed beyond next year.
Bakke said utilities can take advantage of underutilized emissions controls. Bakke also said utilities could install new controls. “That is the most comprehensive way to comply, but it has the most lead time and the most cost,” he said.
“We in the planning department have looked at this and made some suggestions, but now it’s before you,” Bakke said.
The Reliability Subcommittee sent the CSAPR issue to the Steering Committee to downgrade its urgency.
MISO Speeds Up Creation of Pseudo-Tie Congestion Management Process
MISO has proposed a pseudo-tie congestion management process that involves pre-assessment and evaluation stages before pseudo-tie registration is granted. The proposal would be implemented before year-end.
“There’s an urgency in this because we really need these processes in place for reliability,” MISO Senior Director of Regional Operations David Zwergel said.
During the 2015/16 planning year, MISO had only 155 MW of generation pseudo-tied into PJM and most of it was near the seam. MISO now has about 2,000 MW of generation pseudo-tied into its eastern neighbor and much of the generation and load being served is far from the RTO’s seam, resulting in local congestion.
MISO is proposing a new four-step process before activating new pseudo-ties:
- MISO and a neighboring reliability coordinator determine which operational studies are needed;
- MISO and the attaining RTO establish tests to identify market-to-market flowgates using a generation-to-load distribution factor. If the attaining RTO’s results vary from MISO’s by more than 2%, the pseudo-tie is denied;
- MISO works out a reimbursement agreement if a pseudo-tie implementation cost allocation is needed; and
- An asset owner and a MISO local balancing authority agree to install metering to record pseudo-tie flows as required by MISO rules.
MISO’s Kyle Abell said the RTO plans to provide Business Practices Manual and Tariff language in November, with plans for a FERC filing in December. It is asking stakeholders for feedback on the proposal by Oct. 28.
MISO Retires CIP User Group
MISO’s proposal to retire its Critical Infrastructure Protection User Group met with no stakeholder resistance. MISO’s Amanda Bragg said the group was formed three years ago to discuss industry trends and compliance with NERC’s Critical Infrastructure Protection (CIP) standards.
“Over time, the number of attendees has dwindled,” Bragg said.
Bragg also said group discussions have begun “naturally” merging CIP compliance with general information security. She said MISO plans to discuss the issues at security and compliance summits in the spring and fall, which it hopes will draw a bigger crowd.
Solid Reliability in August and September
MISO’s Steve Swan said the RTO’s reliability, markets and operational functions performed well during higher-than-average temperatures in August and September.
Average load in September was 78.8 GW, compared to last September’s 79-GW average. Load peaked on Sept. 6 at 115.1 GW.
In August, load exceeded 110 GW for 56 hours, compared to only six hours in August 2015. Average August load was 88.1 GW, 4 GW higher than a year earlier. Load peaked on Aug. 4 at 119.3 GW. Swan reported August temperatures averaged 3 to 4 degrees higher than the last three years.
“Consistent with higher loads, lower winds and stable fuel prices,” MISO said, real-time prices increased $1.02/MWh in July and $2.20/MWh in August versus 2015. Gas prices at the Chicago averaged $2.75/MMBtu, $0.11/MMBtu less than August 2015.
— Amanda Durish Cook
