By Amanda Durish Cook
Sen. Tina Smith (D-MN) filed comments with FERC early this month, urging the commission to consider that MISO’s generator replacement proposal — currently pending before FERC — stands to benefit renewable generation and could nudge owners of high-emitting generators to make cleaner upgrades (ER19-1065).
In her comments to FERC, Smith said the plan could support the goals behind Minnesota’s Next Generation Energy Act of 2007, which requires the state to reduce its 2050 greenhouse gas emissions to 80% below a 2005 baseline.
“For the electric sector, meeting that goal will require the replacement of high-emitting generators and a continued rapid expansion of low- and non-emitting generators,” she said. “MISO’s proposal will remove incentives for the owners of current high-emitting generators to put off upgrading to low- and no-emission generators by enabling replacement of legacy generating equipment in a manner that avoids significant additional costs.”
Under MISO’s proposal, interconnection customers wishing to replace their generation under the same interconnection agreement would send a request and a $60,000 study deposit to MISO. Over the following 180 days, MISO would conduct a generator replacement impact study similar to its existing material modification study, as well as a reliability assessment similar to its current reliability study for generation retirement.
Upon a finding of no adverse impact from the replacement, MISO would give the customer 30 days to decide to proceed with the replacement project. MISO would then have 90 days to conduct an interconnection facility study, if needed. After that, a replacement project proceeds to negotiation of a draft or amended generator interconnection agreement.
If MISO does find adverse impacts from the study, it would require the interconnection customer to “submit all necessary requirements for a new interconnection request” to begin the definitive planning phase anew. Adverse impacts include increases in thermal loading, a degradation in voltage, a degradation in stability performance and increases in short circuit contribution.
Smith said the proposal will benefit existing wind and solar generators, “ensuring they can continue to replace aging generating equipment with more efficient new equipment as technology improves, also without facing such additional upgrade costs.”
The proposal “facilitates reuse of existing infrastructure, supports state environmental initiatives and helps keep customer costs low,” Smith said, also noting the plant has the support of the American Wind Energy Association and the Clean Grid Alliance.
MISO plans to implement the replacement process by the third quarter of this year. The RTO said the proposal has widespread stakeholder support.