The Solar Energy Industries Association on Tuesday lodged a complaint at FERC against MISO’s practice of blocking intermittent resources from its ancillary service market.
SEIA, represented by Earthjustice, asked that the commission find as unjust and unreasonable MISO’s tariff provisions and business practice procedures restricting wind, solar and battery hybrid resources from providing regulation service, spinning reserves and supplemental reserves.
The organization said the RTO prevents its dispatchable intermittent resources (DIRs) from ancillary services participation “despite the fact that [they] have the operational capability to provide such services.”
“No other FERC-jurisdictional RTO or ISO codifies this explicit discriminatory prohibition,” SEIA said in its filing, noting that PJM and CAISO explicitly state wind and solar resources’ eligibility.
SEIA also pointed out that MISO never meant for its ban on renewable ancillary services to be permanent. In a 2010 filing with FERC, the grid operator said it needed “to gain experience with this new method of modeling and dispatching” before allowing renewable energy to supply operating reserves. SEIA said FERC’s ultimate agreement with MISO’s prohibition hinged on its temporary nature. To date, MISO has never provided a “technical justification” for its ban, the organization said.
It argued MISO’s market rules discriminate against some resources because they’re tailored to the large, centralized power plants of the past.
“MISO’s discriminatory and unjustified tariff provisions that prohibit DIRs from providing ancillary services in MISO’s wholesale market is a prototypical example of how outdated tariff provisions can result in unnecessary and deleterious market barriers,” the organization said.
SEIA said lifting the ban would increase competition and allow new resources to “provide the critical grid-stabilizing services that MISO will need.” It said that though MISO “fundamentally agrees” that renewable resources should be able to provide all the services they’re capable of, the grid operator hasn’t acted on a longstanding suggestion that it extend its ancillary service market to renewable energy. According to SEIA, the issue was raised as part of MISO’s 2018 market roadmap improvement ideas; staff last year recommended putting the idea to rest without action.
The complaint comes as MISO has announced plans to ban dispatchable intermittent resources from providing ramping needs, saying they’re historically unhelpful. (See MISO Plans to Bar Intermittent Resources from Ramp Capability.)
“Rather than doubling down on nonmarket-based blanket prohibitions, MISO ought to be focused on facilitating technology-neutral, operations-focused solutions that properly establish criteria for when a resource is called upon to provide ancillary services,” SEIA said.
In a press release accompanying the complaint, Earthjustice attorney Aaron Stemplewicz said his organization is prepared to challenge MISO’s “attempts to strip wind, solar and battery hybrid resources from providing ramp capability.”
“Any backsliding will be rigorously challenged with regard to the eligibility of renewable resources to provide all the services they are capable of providing,” he said.
SEIA Energy Markets Director Melissa Alfano added that energy markets must keep pace with a changing grid.
“Renewable assets like solar, storage and wind have more than proven themselves as reliable, and we need to recognize the full scope of their benefits if we want to rapidly decarbonize in the next 10 years,” she said.
