Protest of Community Collaboration on Climate Change, et al. re the Midcontinent Independent System Operator, Inc.’s filing proposing revisions to establish the Zero Injection Generator Interconnection Agreement
Read topic-matched comments in ER26-3552
Topics in the text: Connecting load and generation · Cost allocation · Reliability and curtailment
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Source sections
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Opening text
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1 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Midcontinent Independent System Operator, Inc.Read this passage
I. INTRODUCTION
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I.Read this passage
INTRODUCTION
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Without proper tariff provisions, this process could have the opposite of MISO’s intended effect by instead operationalizing ongoing cost shifts that will be difficult, if not impossible, for states to untangle, triggering otherwise preventable reliability shortalls, and allowing generators with…Read this passage Filed comments: Cost allocation
TABLE OF CONTENTS
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TABLE OF CONTENTS I.Read this passage
D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will Be Paid
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D.Read this passage
II. ARGUMENT
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II.Read this passage
A. The Proposal Fails to Actually Ensure Zero Injection by ZG Generators.
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A third infirmity in ensuring that zero means zero is how MISO proposes to set the “Transient Tolerance Window,” which is “the period of time after a reduction or loss of load by the ZG Associated Load by the end of which window the [ZG] Generating Facility must have” ceased injections to the…Read this passage Filed comments: Connecting load and generation
B. The Proposal Lacks Required Transparency.
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The Commission found in the Show Cause Order that MISO must provide “cost transparency measures […] to provide stakeholders with sufficient information and visibility regarding the Network Upgrades, and their associated costs, needed to provide transmission service to Eligible Customers on behalf…Read this passage Filed comments: Connecting load and generation
C. The ZGIA Program’s Scope Should Have a Defined Limitation.
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While acknowledging stakeholders’ “[r]equests to ensure ZGIA is a transitional construct and does not replace the standard GIA process,” MISO wholly ignored the point in its response to related comments: 63 To achieve the narrow tailoring required by the Commission’s open access precedents, a…Read this passage Filed comments: Connecting load and generation
D. The Proposal Fails to Adequately Mitigate the Risk that Network Upgrades Will
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X, Generator Interconnection Procedures, Section 3.2.5.1(2); see also id. at 3.2.5.2.1 (“For ZG Interconnection Service to be granted, these analyses must determine that no Network Upgrades are needed to maintain system reliability other than Network Upgrades at the same substation as the Point of…Read this passage Filed comments: Connecting load and generation
E. The Proposal Requires Greater Clarity on the Treatment of Hybrid Resources.
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Additionally, a ZG Generating Facility shall be metered “separate from any metering used for the ZG Associated Load,”93 but the Proposal should clarify whether a constituent storage unit within a ZGIA Hybrid Resource must be separately metered from the constituent generator and whether its charging…Read this passage Filed comments: Connecting load and generation
F. Drafting Errors
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X, App’x 19 § 9.7.4.7 (requiring a ZG Generating Facility to reduce injections to match the ZG Associated Load’s Demand). 28 To support a ZG Generating Facility’s requirement to avoid grid injections and produce only the power its ZG Associated Load demands, MISO proposes to require that, after a…Read this passage Filed comments: Connecting load and generation
III. CONCLUSION
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III.Read this passage
CONCLUSION
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CONCLUSION To effectuate MISO’s zero injection concept without raising the risk of adverse reliability events and cost shifts, Community Organizations and Clean Energy Advocates respectfully ask the Commission to use its authority to help MISO course correct.Read this passage Filed comments: Cost allocation
CERTIFICATE OF SERVICE
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Wacker Dr., 14th Floor Chicago, IL 60606 sdoshi@earthjustice.orgRead this passage