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Storage advocates urge FERC to reject MISO's Order 841 compliance extension request

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Storage advocates urge FERC to reject MISO's Order 841 compliance extension request

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MISO seeks further extension to March 1, 2025

Opponents say request is unjustified, disruptive

Raises concerns that storage projects could be delayed

Midcontinent Independent System Operator's request to delay by nearly three years its plans for eliminating barriers to electric storage resources' participation in its wholesale power markets drew pushback from clean energy advocates and utilities in the region pursuing development of storage projects.

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In comments due to the Federal Energy Regulatory Commission March 19, several parties asserted that the request to defer implementation was unexpected, unjustified, and disruptive to the deployment of storage resources in MISO's footprint.

Order 841 (AD16-20, RM16-23) directed each regional transmission organization and independent system operator to create market participation rules that recognize the unique physical and operational characteristics of electric storage resources.

FERC in November 2019 largely accepted MISO's plan to comply (ER19-465) with the order and granted a request to defer implementation of the Order 841 requirements until June 6, 2022, to accommodate other major market and reliability enhancements, namely the creation of a short-term reserve market product.

Extension request

The grid operator on March 4 asked FERC to further extend to March 1, 2025, the effective date for its tariff provisions to comply with Order 841. MISO argued that the deferment would allow it to accelerate completion of the market system enhancement (MSE) software platform that is set to replace the existing platform in 2025 to better address reliability challenges arising from the fast growth of renewable resources.

"Excusing MISO from implementing [electric storage resources (ESRs)] in MISO's soon-to-be-replaced existing system, will facilitate the MSE's establishment by 2024 instead of 2025," the grid operator said in its request.

Several trade groups countered that "MISO's request ignores the detrimental impact that a further delay in the implementation of the tariff provisions will have on ESRs that had reasonably planned for interconnection and operation based upon the existing MISO-requested, commission-approved operational date of June 6, 2022."

The US Energy Storage Association, American Clean Power Association, Clean Grid Alliance, Solar Energy Industries Association, Advanced Energy Economy and Southern Renewable Energy Association, collectively referring to themselves as the Clean Energy Coalition, added that MISO's request failed to satisfy the commission's criteria for granting a waiver of tariff provisions. That review by FERC considers whether the applicant acted in good faith and whether the request is limited in scope, remedies a concrete problem and lacks undesirable consequences for third parties.

"First, MISO cannot satisfy the commission's good faith requirement due to its failure to keep stakeholders fully informed," the coalition said, pointing to a November 2020 filing from MISO affirming that implementation of the MSE and Order 841 were on track. That annual informational filing on progress toward implementing Order 841 was directed by FERC when it granted the implementation extension in 2019.

"Second, the waiver is of significant scope, as it impacts the capacity, energy and ancillary services markets, and all ESR participants prepared to operate in those markets," the Clean Energy Coalition said. "Third, upgrading the [MSE] software before implementing the Order 841 [market rules] might be administratively beneficial (at least in MISO's view), but is hardly a resolution to a 'concrete problem.' Fourth, the waiver would have undesirable consequences, such as harming third parties that include the Clean Energy Coalition's members."

Impacts regulatory certainty

A separate protest filing from NextEra Energy Resources, which said its subsidiaries were developing various storage resources in MISO, contended that the delay MISO sought would significantly impact the regulatory certainty needed to develop those resources.

"Instead of being able to rely on a June 2022 date for deploying storage resources consistent with Order No. 841, developers must now wait several more years," NextEra said. "This delay is unacceptable and should be rejected by the commission."

Among its reasons for needing to accelerate MSE implementation ahead of Order 841 compliance, MISO, in its request, noted findings from its Renewable Integration Impact Assessment (RIAA) that penetration of wind and solar resources in the region may reach or exceed a critical threshold of 30% of MISO's load as early as 2026.

NextEra, however, pointed to the RIAA's finding that storage can help manage the integration of renewable energy as it tends to flatten the net-load curve and spread out the loss of load risk.

"But MISO's proposed delay would deprive it of the full advantage of storage resource integration as required by Order No. 841," NextEra said. "If MISO is concerned with having more tools to manage renewable energy integration, it should continue on its path and have the ESR software operational by June 2022."

Wisconsin Electric Power, Wisconsin Public Service, and Upper Michigan Resources, as well as Alliant Energy also filed comments expressing concerns that developers may delay ESR investments until Order 841 takes effect in the region, and that the requested delay would deprive market participants of gaining experience with the market rules that will be in place over the long term.