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Energy Storage as Transmission Asset - MISO

In ER20-588, FERC recently suspended for five months proposed changes to the MISO tariff to accommodate energy storage as a transmission asset.  They ordered Staff to have a technical conference.  Below is the key paragraph from the Order, which is attached.

  1. “Our preliminary analysis indicates that the proposed revisions to MISO’s Tariff have not been shown to be just and reasonable and may be unjust, unreasonable, unduly discriminatory or preferential, or otherwise unlawful.  We find that MISO’s filing raises issues that cannot be resolved based on the record before us and are more appropriately addressed in a technical conference.  Accordingly, we accept the proposed Tariff revisions for filing, suspend them for five months, to become effective on August 11, 2020, subject to refund, and direct Commission staff to hold a technical conference in this matter.  Issues to be addressed include, but are not limited to, MISO’s proposed evaluation and selection criteria for SATOAs, the SATOA’s market activities and any potential wholesale market impacts of those activities, how MISO’s current formula rate structure accommodates cost recovery for SATOAs, a SATOA’s potential impact on the generator interconnection queue, and operating guides that will apply to a SATOA.  Commission staff will include the details of the technical conference in a subsequent notice.  Following the technical conference, parties will have an opportunity to file written comments that will be included in the formal record of the proceeding, which, together with the record developed to date, will form the basis for further Commission action.”
Paul Dumais's picture

Thank Paul for the Post!

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Matt Chester's picture
Matt Chester on Mar 11, 2020 9:14 pm GMT

If I'm reading correctly, the technical conference happens first and then public comment-- is there a reason they wouldn't be soliciting comment at this stage to take into account in the technical conference? 

Paul Dumais's picture
Paul Dumais on Mar 13, 2020 2:07 am GMT

You are correct.  They have already received many comments during the 60 day period from when MISO filed and this FERC Order.  FERC knows what they want Staff to cover in the TC.  Therefore, no additional comments are desired until after the TC.  

Patrick McGarry's picture
Patrick McGarry on Mar 16, 2020 1:46 pm GMT

Paul- Thanks for the post. Battery storage will introduce significant complexity to the current market design.I believe that to be so because storage offers several different value streams. I dont ever recall a product that can both be load & gen as well as an alternative to transmission. I think all the RTOs/ISOs will struggle out of the gate. My sense is that stakeholders are still trying to understand the basic essentials of battery storage, -Patrick

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