Earthjustice, an environmental law organization, filed a complaint with the Federal Energy Regulatory Commission (FERC) on behalf of the Solar Energy Industries Association (SEIA), challenging a rule that prohibits renewables from providing ancillary services. The rule was instituted by grid operator Midcontinent Independent System Operator (MISO) in 2011 and never challenged.
With this rule, MISO is the only FERC jurisdictional grid operator to explicitly prohibit wind, solar, and battery hybrid resources from providing ancillary services, Earthjustice reports. Ancillary services help grid operators maintain a reliable electricity system, balance supply and demand, ensure reliability during extreme weather events, and help the system recover after a power system outage. Allowing wind, solar and battery hybrid resources, known as dispatchable intermittent resources, to be eligible to provide ancillary services could lower overall system costs, and could make the grid more reliable and resilient to extreme weather and climate disasters.
The complaint states that MISO’s practices prohibit dispatchable intermittent resources (DIR) such as solar, wind and battery resources, from participating in MISO’s ancillary services market. The complaint claims that the prohibition “excludes DIRs from the opportunity to provide certain ancillary services – including regulation services, spinning reserves, and supplemental reserves – despite the fact that DIRS have the operational capability to provide such services”.
Earthjustice states in the complaint that MISO is alone in this “explicit discriminatory prohibition,” as other FERC regional transmission organizations (RTO) or independent system operators (ISO) find that wind and solar resources are eligible to provide these services. Ultimately, these tariff provisions can result in “unnecessary and deleterious market barriers”.
The Complaint requests two primary actions:
- That the Commission find that MISO Tariff provisions and business practices manual protocols prohibiting wind, solar, and battery hybrid resources from providing the ancillary services that they are technically capable of providing are unjust, unreasonable, and unduly discriminatory or preferential pursuant to the FPA; and
- That the Commission order MISO to reform the current ancillary service Tariff provisions and business practices manual to allow wind, solar and battery hybrid resources to be eligible to participate in MISO’s ancillary services wholesale market. The Commission should direct that MISO’s Tariff and business practices manual be reformed with a technology neutral approach so that all resources technically capable of providing various ancillary services products under the Tariff be permitted to provide such products.
MISO serves 45 million people in 15 states and the Canadian province of Manitoba, with a reported $40 billion in annual transactions. The amount of energy produced from wind and solar is expected to increase significantly in the MISO region in the coming years, all of which have proven the ability to provide ancillary services, according to Earthjustice.
“Regional transmission authorities should not restrict the services that renewables can provide,” said Aaron Stemplewicz, senior attorney of Earthjustice. “Any backsliding will be rigorously challenged with regard to the eligibility of renewable resources to provide all the services they are capable of providing,” he said.
“For the last decade, the MISO has been discriminating against renewable generators, and it’s time that FERC corrects the record and gives renewables a fair shot,” said Melissa Alfano, director of energy markets and counsel at the Solar Energy Industries Association (SEIA). “The fact is the grid is changing and energy markets need to keep up. Renewable assets like solar, storage and wind have more than proven themselves as reliable, and we need to recognize the full scope of their benefits if we want to rapidly decarbonize.”
MISO also plans to file a request with FERC to remove ramp capability eligibility for renewable resources as well. Ramp capability refers to the ability of a power system to quickly increase or decrease its output to accommodate changes in electricity demand. Ramp shortages are the most common cause of short-term scarcities and price spikes.
Stemplewicz said that Earthjustice will also challenge any attempts to strip wind, solar and battery hybrid resources from providing ramp capability.
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