Energy Storage in the MISO Footprint
Two new energy storage studies are getting underway this summer in the Midwest Independent System Operator (MISO) footprint: the Energy Storage Study and the Manitoba Hydro Wind Synergy Study. At MISO’s Energy Storage Workshop held on June 29, 2011, MISO explained that its goals are to explore the potential reliability, market, and planning benefits of energy storage technologies and estimate the price inflection point where energy storage provides benefits to MISO markets.
The Energy Storage Study will focus on battery technology, compressed air, and pumped storage. The first phase of the study will be completed in November 2011 and a second phase by the end of June 2012. MISO’s new Energy Storage Technical Review Group will meet for the first time on August 3, 2011, when it will consider the Draft Energy Storage Study Scope. The Manitoba Hydro Wind Synergy Study will focus on Manitoba Hydro’s capabilities as essentially a “super-sized pumped storage plant.”
These studies are the next steps in MISO’s efforts to incorporate long-term storage into its markets. In February 2008, a FERC Order on Ancillary Market Services directed MISO to evaluate operational and procedural adjustments to remove barriers to the comparable treatment of new technologies (Docket No. ER07-1372). In a December 31, 2009 Order, FERC conditionally accepted MISO tariff provisions for Stored Energy Resources (Docket No. ER09-1126), finding that the operating requirements and compensation for Stored Energy Resources would be comparable to other resources providing regulating reserves. Pursuant to the December 31, 2009 Order, MISO also submitted an informational report to FERC on March 1, 2010 describing its efforts to incorporate long-term storage resources into the market. The two energy storage studies starting this summer move these efforts to a formal study phase.
Renewable Energy Law Alert: The Upper Midwest Reopens to Renewable Energy Development
Yesterday, December 16, 2010, the Federal Energy Regulatory Commission (FERC) conditionally approved a proposal by the Midwest Independent Transmission System Operator (MISO) that significantly changes how large transmission upgrades are funded across the MISO region.
MISO’s proposal creates a new category of transmission projects called Multi-Value Projects (MVPs) for upgrades that are determined to enable reliable and economic delivery of energy in support of public policy mandates or laws that address transmission reliability and congestion across multiple transmission zones.
MISO’s proposal is effective as of July 16, 2010 and thus applies to transmission projects identified in Appendix A of 2010 MISO Transmission Expansion Plan (MTEP).
To continue reading, click here.
If you have any questions about the order, how it may affect your generation or transmission project, or wind energy development in the Midwest, please contact one of the following attorneys:
Minneapolis, MN
Mark Hanson at (612) 373-8823 or mjhanson@stoel.com
Kevin Johnson at (612) 373-8803 or kdjohnson@stoel.com
Kevin Prohaska at (612) 373-8805 or krprohaska@stoel.com
David Quinby at (612) 373-8825 or dtquinby@stoel.com
Joe Thompson at (612) 373-8822 or jrthompson@stoel.com
Sarah Johnson Phillips at (612) 373-8843 or sjphillips@stoel.com
Portland, OR
Jennifer Martin at (503) 294-9852 or jhmartin@stoel.com
Marcus Wood at (503) 294-9434 or mwood@stoel.com
Sara Bergan at (503) 294-9336 or sebergan@stoel.com
Jason Johns at (503) 294-9618 or jajohns@stoel.com
Midwest ISO Final MVP Cost Allocation Proposal Won't Charge Generators for New Transmission Needed for Wind Energy
From our colleague Sarah Johnson Phillips: Although the proposal spreads the cost of MVPs across the Midwest ISO, the new proposal keeps the current cost sharing methodology for generation interconnection projects. All interconnection costs would be allocated to the interconnecting developer, except 10% would be shared by load for large facilities (345 kV and above). The proposal also addresses the generator interconnection cost “free rider” problem by allowing earlier projects to be reimbursed by later projects using the same upgrades. This cost allocation for generator interconnection was imposed by the Midwest ISO in 2009 as an interim measure to address what is known as the “Otter Tail problem” It shifted virtually all interconnection costs to developers and relieved transmission owners and their ratepayers from contributing to upgrades that reinforce the grid to everyone’s benefit. See our blog entry from last year for more history on the Midwest ISO cost allocation controversy.
Much to the relief of wind developers in the Midwest, the Midwest ISO has backed off a plan to charge new and existing generators 20% of the cost of new transmission needed to meet renewable energy development goals.
Yesterday, the Midwest ISO released its final cost allocation proposal, which it will file with the Federal Energy Regulatory Commission on July 15, 2010. In the final proposal, the cost of Multi-Value Projects (MVPs) will be spread evenly to load throughout the MISO footprint on an energy basis. MVPs are transmission projects needed to support renewable energy development, other policy drivers, or have multiple benefits such as reliability and market efficiency. Previous cost allocation proposals would have allocated 20% of the cost of MVPs to new and existing generators. That potential cost burden and resulting cost uncertainty had caused some wind industry observers to speculate that wind projects would abandon the Midwest for other parts of the country where transmission is cheaper.
Wind industry advocates, such as Wind on the Wires, still hope to clarify some additional issues in the cost allocation proposal—such as clearer criteria for what qualifies as an MVP and a plan for how to transition from the current system to the new system. Some of these outstanding issues could yet be addressed between now and the July 15th filing.
At this point it is difficult to know if the MVP proposal will result in most major upgrades being paid for by loads, with generators paying for only modest network upgrades under their generator interconnection agreements. But, for now, removal of the 20% charge to generator for MVPs is a big victory for wind development in the Midwest. If wind developers continue to experience attempts to impose the cost of major transmission projects on them, the victory on the MVPs will be a pyrrhic one.
Affordable new transmission for wind energy is critical for Midwestern states to meet their renewable energy mandates and to achieve the regional goals set by the Midwestern Governors Association of 10% renewable electricity by 2015, 20% by 2020, and 30% by 2030.
A summary of the Midwest ISO Final Cost Allocation proposal, as presented to the Regional Expansion Criteria & Benefits (RECB) Task Force yesterday, is available here.
FERC Conditionally Approves MISO Tariff Amendment on Cost Allocation
This afternoon, the Federal Energy Regulatory Commission conditionally approved the Midwest Independent Transmission System Operator's (MISO) proposed tariff amendment regarding allocating the cost of network upgrades for generation interconnection projects meeting MISO's regional expansion criteria and benefits (RECB) standards. See my previous blog entry for a more detailed discussion on the history of the tariff amendment, as well as protests to the amendment filed by AWEA and others.
Under the decision rendered today, FERC found that the proposed solution provides an interim solution, and directs MISO to make a compliance filing (1) to fulfill its commitment to file superseding tariff revisions regarding the Phase II cost allocation methodology on or before July 15, 2010, and (2) to reflect certain conforming changes to its tariff. In addition, FERC expects MISO to provide the Commission with status reports on the Phase II process.
To see any of the documents filed in this proceeding, go to FERC's eLibrary website and enter in Docket No. ER09-1431.
FERC Issues MISO Letter of Deficiency on RECB Cost Allocation Issue
On September 2, 2009, the Federal Energy Regulatory Commission issued a letter of deficiency to the Midwest Independent Transmission System Operator in MISO's RECB Phase I generator interconnect cost allocation tariff amendment proceedings (Docket No. ER09-1431). See my previous blog entry on AWEA's protest to the MISO filing for additional background.
The letter instructs MISO to provide certain supplemental information within fifteen days. Specifically, MISO is instructed to provide a list of all of the interconnection projects that will be affected by the tariff amendment, an explanation of MISO's position on the relevant date for determining which cost allocation method methodology will apply, and additional support for certain statements made in its filing regarding attrition rates and elimination of certain requirements of interconnecting generators resulting from the filing. Finally, MISO is instructed to provide a timeline and description of the anticipated RECB Phase II methodology stakeholder process that will be followed to permit MISO to meet its commitment to file a succeeding tariff proposal by July 15, 2010.
AWEA, Others File Protests at FERC to MISO Proposed Cost Allocation
On August 13, 2009, the American Wind Energy Association, Wind on the Wires and certain wind developers filed protests at the Federal Energy Regulatory Commission to the Midwest Independent Transmission System Operator's (MISO) recent filing at FERC. The MISO filing proposes to revise MISO's cost allocation methodology for network upgrades for generator interconnection, and resulted from MISO's Regional Expansion Criteria & Benefits (RECB) Task Force.
The current cost allocation methodology in place provides that the cost of network upgrades for generator interconnection are funded initially by generator interconnection customers, and the customer is entitled to a 50% reimbursement where it is demonstrated that the output will serve MISO’s network customers or the facility has been designated a network resource. For facilities rated 345 kV and higher, 20% of the refund cost is allocated to all MISO pricing zones on a postage-stamp basis, and 80% is allocated among pricing zones using a line outage distribution factor (LODF) method.
Under the MISO proposal, cost allocation would be as follows: (i) for network upgrades below 345 kV, 100% to the interconnection customer, and (ii) for network upgrades 345 kV and above, 90% to the interconnection customer and 10% to all transmission customers through a postage stamp-type charge.
To read any of the documents related to the MISO filing, go to the FERC eLibrary website and enter in Docket No. ER09-1431.
FERC Rejects MISO's Market Coordination Service Proposal, Approves Anchor Tenant Merchant Transmission
From our colleague and FERC guru, Jason Johns:
MISO’s Proposed Market Coordination Service:
The Federal Energy Regulatory Commission today rejected the Midwest ISO’s proposed Market Coordination Service that would have given certain transmission owners access to the ISO energy and operating reserve markets without requiring those owners to hand over control of facilities or share in transmission development costs. Although the proposal was an innovative approach to expanding the ISO’s market footprint, FERC worried that the proposal would harm consumers and cause the ISO to unravel as transmission owners opt out of full membership to avoid transmission cost-sharing. FERC also questioned whether the proposal would attract more wind energy into the ISO market because, by leaving pancaked transmission rates intact, wind resources could face higher transmission rates as ISO members withdraw in favor of Market Service. The Midwest ISO must remove all Market Service language from its tariff within the next 30 days.
Renewable Energy Transmission Project Rates:
In other news, FERC accepted a request for waiver of criteria traditionally used to evaluate merchant transmission projects. In their applications, the Zephyr and Chinook merchant transmission projects proposed to presubscribe 50% of the projects’ 3,000 MW capacity to an “anchor tenant” wind developer in order to defray upfront development costs, and then allocate the remaining 50% through a traditional open season process. The proposal was intended to avoid the “chicken-and-egg” scenario often associated with merchant transmission, i.e.,resources will not develop without assurances that transmission is available, and likewise transmission projects will not move forward without assurances from resource developers. FERC’s acceptance of this modified approach to merchant transmission expressly opened the door to similar proposals in the future. “Anchor tenant” merchant transmission is the new standard.
Client Alert: FERC's Conditional Approval of MISO Queue Reform
Check out our client alert on FERC's recent conditional approval of MISO's revised large generator interconnection process. It provides highlights of the ruling and identifies next steps that MISO must take in order to flesh out some issues, including certain milestones that generators must meet in order to move towards getting their project interconnected.
Beth Soholt, executive director of Wind on the Wires, believes that the ruling is pretty consistent with what those in the industry expected, and that the intent was to give generators a more clear picture up front of what the actual costs are for carrying a project through to interconnection. She thinks that we'll have to wait and see how MISO interprets the clarification requirements, and how generators respond to the new process, to really understand what the impact will be and whether this will result in a material change in the number of projects entering the queue.
Stay tuned!
FERC Rules on MISO Queue Reform Proposal
On August 25, FERC issued its ruling on the Midwest Independent Transmission System Operator (MISO) plan to reform the generator interconnection queue process - the method by which transmission requirements for generators wishing to connect new projects to the grid in the Midwest are reviewed and approved. FERC conditionally accepted the proposed tariff revisions, with an effective date of August 25, 2008, and directed MISO to make a compliance filing within 30 days of the Order. Major changes include addition of a Pre-Queue Phase, addition of a Fast Track Process, revisions to the amount and timing of deposits, revisions to the milestones projects must meet to move forward, and limitations on the ability to suspend.
Watch for a client alert shortly!
