Upper vs. Lower Case BTMG. Resource Adequacy Subcommittee October 11, 2017

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Austin Small
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1 Upper vs. Lower Case BTMG Resource Adequacy Subcommittee October 11, 2017

2 Purpose & Key Takeaways Purpose: Address issue assigned to RASC by SC: Define lower case btmg and/or criteria such as MW threshold or voltage threshold Key Takeaways: Better alignment between Module B and Module E is needed Designation of Network Resources BTMG and btmg require clear definitions and requirements within the tariff and BPMs 1

3 Tariff Definition Behind the Meter Generation (BTMG): Generation resources used to serve wholesale or retail load located behind a CPNode that are not included in the Transmission Provider s Setpoint Instructions and in some cases can also be deliverable to Load located within the Transmission Provider Region using either Network Integration, Point-To-Point Transmission Service or transmission service pursuant to a Grandfathered Agreement. These resources have an obligation to be made available during Emergencies. No distinction between generation behind the meter that is used by a Network Customer to serve its Network Load and generation owned by a retail customer used to manage its load, consistent with the provisions of the applicable retail tariff 2

4 Tariff Requirements Module B: Section 30.1 Designation of Network Resources Network Resources shall include all generation owned, purchased or leased by the Network Customer designated to serve Network Load under the Tariff. Network Resources may not include Generation Resources, or any portion thereof, that are committed for sale to non-designated third party Load or otherwise cannot be called upon to meet the Network Customer s Network Load on a non-interruptible basis, except for purposes of fulfilling obligations under a reserve sharing program. Section 30.7 Limitations on the Designation of Network Resources The Network Customer must demonstrate that it owns or has committed to purchase generation pursuant to an executed contract in order to designate a Generation Resource as a Network Resource. 3

5 Tariff Requirements Module B: Section 29.2: A statement signed by an authorized officer from or agent of the Network Customer attesting that all of the Network Resources listed pursuant to Section 29.2(v) satisfy the following conditions: (1) the Network Customer owns the Resource, has committed to purchase generation pursuant to an executed contract, or has committed to purchase generation where execution of a contract is contingent upon the availability of Transmission Service under Part III of the Tariff; and (2) the Network Resources do not include any Resources, or any portion thereof, that are committed for sale to non-designated third party load or otherwise cannot be called upon to meet the Network Customer's Network Load on a noninterruptible basis, except for purposes of fulfilling obligations under a reserve sharing program; 4

6 Tariff Requirements The Tariff does not allow a Network Customer to claim the MISO Market or MISO Capacity Market as its network resource No firm or contractual rights to the market MISO PRA can clear at CONE but not fulfill capacity requirements LRZ s LCR could drive price to CONE in LRZ even though excess capacity in other LRZs Gap between Module B and Module E Module B designation of network resources doesn t recognize Module E acquired capacity 5

7 Proposal Define upper and lower case BTMG consistent with tariff requirements for Network Integration Transmission Service (NITS) Network Customers must specify their Network Resources at time of NITS request, including those behind the meter (market meter or market delivery point) Proposal does not explicitly address the netting of behind the meter generation with load for network load reporting, billing and transmission planning purposes Assigned to PAC 6

8 Proposal Uppercase BTMG (UC-BTMG): Any Network Resource of a Network Customer located behind the market delivery point Any resource behind the market delivery point participating in the market (including aggregated DERs) Any resource behind the market delivery point that causes flow on the transmission system Must be registered with MISO DERs = Distributed Energy Resources 7

9 Proposal Lowercase BTMG (LC-btmg): Any generation resource located behind the retail meter that is not a Network Resource and is owned/dispatched by a retail customer to manage its load at the same electrical location Not registered with MISO 8

10 Suggestions for PAC PAC issue but intent of this proposal: UC-BTMG shall not net with load for network load reporting, billing and transmission planning purposes LC-btmg can net with load for network load reporting, billing and transmission planning purposes Load served by LC-btmg (above a threshold 5 MW?) must be curtailable/interruptible under applicable retail tariff provisions in order to net with load Addresses forced outage of LC-btmg that could result in a significant impact to the transmission system May need to consider a cutoff threshold for small DER (ie less than 1 MW at delivery location is simply incorporated into the load characteristic) 9

11 Examples Network Customer s Network Resource connected behind the market delivery point EP or CP Node 2 MW 2 MW 2 MW 5 MW UC-BTMG = 5 MW Network Load = 6 MW 10

12 Examples Municipal Electric System connected behind the market delivery point (assumes NITS requested for entire 66 MW load) EP or CP Node 2 MW 2 MW 2 MW 50 MW Other load delivery points = 60 MW UC-BTMG = 50 MW Network Load = 66 MW 11

13 Examples Industrial Customer with on-site generation connected behind the market delivery point EP or CP Node 2 MW 2 MW 2 MW 20 MW 25 MW LC-btmg = 20 MW Network Load = 11 MW 12

14 Questions and Comments contact info: Christopher Plante Manager FERC Electric Regulatory & Policy WEC Energy Group Business Services office: mobile: Serving WEC Energy Group - We Energies, Wisconsin Public Service Corp & UMERC

I. Tariff language for Transmission Losses Applied to Monthly Reported Network Loads: (for tariff)

I. Tariff language for Transmission Losses Applied to Monthly Reported Network Loads: (for tariff) * MISO will add the underlined text provided by the Owners Committee to Section 34.2 of the Tariff with