At FERC’s urging, MISO is considering removing confidentiality around generators that notify it of their intent to suspend or retire.

“FERC recommended MISO should explore and work with stakeholders to see if we need to change the confidentially provisions,” explained Neil Shah, MISO adviser of seams administration, during the Nov. 16 meeting of the Planning Advisory Committee.

FERC made the suggestion in an August order (ER16-1758) that largely accepted changes to MISO’s system support resource procedure. (See “MISO Planning Confidentiality, Notification Changes to Attachment Y Procedure,” MISO Planning Advisory Committee Briefs.) The commission recommended that MISO might follow PJM’s lead in notifying the public of future suspensions and deactivations as the notices are received.

“We recognize that PJM provides for even greater transparency by subjecting all official future generator deactivation requests to public notice,” FERC said. “We also encourage MISO independently to explore the possibility of allowing for greater transparency due to changing market conditions, further experience with the SSR and transmission planning processes, or other factors.”

If confidentiality is lifted, MISO would be able to publicly identify all generators that submit Attachment Y notices. Currently, the RTO keeps Attachment Y information confidential until the effective date of retirement unless its reliability study uncovers a reason to keep the unit online as an SSR or the resource owner has already disclosed the upcoming retirement.

“We definitely see merit in removing confidentiality,” Shah said. “It does help other resource owners understand the changing resource mix in MISO on a proactive basis rather than reactively.”

Shah said some generation owners submit Attachment Y notices as much as two years in advance. MISO requires six months’ notice.

MISO also said making the information public would help owners make new investments and site new projects more quickly and would facilitate more transparent discussions about reliability needs and the most useful transmission projects. Shah said having retirement notices from the start would be useful to the RTO’s Subregional Planning Meetings and its Economic Planning User Group.

Hwikwon Ham of the Minnesota Public Utilities Commission said state regulators should be involved at the beginning of retirement and suspension notices. “I think it’s now more relevant to release this data ahead of time so everyone can make a fair evaluation” for state resource planning processes, Ham said.

Shah asked for written feedback by Dec 2.

Storage Projects to be Included in Queue Rules — For Now

MISO is amending its generation interconnection Business Practices Manual to include interconnecting energy storage devices.

Shah said storage projects wishing to enter the interconnection queue will be treated like other resources and language will be added to Business Practices Manual 015 to expressly include such devices.

Energy storage projects seeking a new interconnection can follow the documented standard process to interconnect a new facility. Customers that already have an interconnection and wish to connect storage projects must request either a material modification study if their project will not exceed the megawatt estimate on their generation interconnection agreement or request an increase in generation capacity study if the megawatt amount will exceed what was estimated in the agreement.

Finally, customers wanting to connect a storage project to a pre-existing point of interconnection that they do not own must either make sure their connection will not exceed the megawatt value from the original agreement or be an affiliated company with a separate generation interconnection agreement.

Shah said the point of the BPM change is to cut a clear path for energy storage wishing to provide generation or capacity. He asked for stakeholder input by Dec. 2 and said MISO would return with updated language at the December or January PAC meeting.

Sam Gomberg, an energy analyst in the Midwest office of the Union of Concerned Scientists, asked if the rules would be open to future changes that accommodate the unique abilities of storage. He said he was seeking reassurance that MISO isn’t “foreclosing” on a more flexible process in the future.

MISO PAC liaison Jeff Webb said a larger discussion on storage integration will continue. “We do need to be prepared with basic procedures to handle immediate requests, and I think that’s what this language sets out to do,” Webb said.

Shah said the clarifying language does not require a Tariff change.

Quarterly Operating Limit Studies Charge Moved to Separate Filing

Because FERC has rejected MISO’s queue reform filing, the RTO plans make a separate filing to begin charging interconnection customers for Quarterly Operating Limit (QOL) studies, MISO’s Paul Muncy said.

Muncy said MISO has decided to pull the QOL cost responsibility language out of the larger queue reform filing in the hopes of quicker FERC approval. QOL studies determine a generating facility’s maximum permissible output.

The revised QOL language would require customers to make a $10,000 study deposit 60 days before a binding quarter begins. Differences between the actual study cost and deposit will be refunded or billed to the interconnection customer.

Because MISO plans to charge for the studies, interconnection customers will be able to opt out of the study, Muncy said.

“The QOL study may give you additional capacity for each quarter, but we do have some customers who may decide that ‘eh, it’s only one or two additional megawatts,’” Muncy said.

Muncy asked for stakeholder feedback on the proposed filing by Dec. 7.

— Amanda Durish Cook