FERC Accepts MISO Proposal to Require Dispatchable Intermittent Resource Registration for Solar Projects

In an order issued June 9, 2020, FERC accepted a proposal from the Midcontinent Independent System Operator, Inc. (“MISO”) to require certain solar generating facilities to respond to real-time dispatch signals by registering as Dispatchable Intermittent Resources (“DIRs”).  Through MISO’s proposal, all solar resources entering commercial operation on or after March 15, 2020 must register as DIRs and become dispatchable by March 15, 2022, whereas solar resources in operation before March 15, 2020 have the option, but are not required, to obtain DIR registration.  In accepting the proposal, FERC rejected arguments from one protestor that the proposal unduly burdened solar projects in late-stage development, finding that MISO’s proposed two-year transition period for such resources was reasonable.

As first established in 2011 for wind resources in MISO, DIR registration requirements obligate a generator to install various metering, communications, and other control technologies for purposes of responding to real-time security constrained economic dispatch signals.  Variable energy resources that are not registered as DIRs are manually dispatched by MISO for congestion and load management purposes and are, consequently, unable to participate in MISO’s real-time market.

Citing increasing levels of solar penetration, on December 13, 2019, MISO submitted its proposal to extend the DIR requirements to solar resources.  Specifically, as proposed in December and amended through a subsequent deficiency response on April 10, 2020, MISO revised its Open Access Transmission, Energy, and Operating Reserve Markets Tariff (“Tariff”) and pro forma GIA template to require all solar-fueled resources interconnecting to the MISO Transmission System on or after March 15, 2020 to register as DIRs.  MISO also proposed a two-year transition period for solar resources with executed GIAs but that had not yet achieved commercial operation.  Under MISO’s proposal, solar resources that are already in commercial operation before March 15, 2020 would have the option to register as DIRs.

Various parties and developers intervened, with some submitting comments in support of, and opposition to, the proposal.  Notably, one developer protested that MISO’s proposal would unduly burden solar projects in later stages of development.  MISO responded that, because of the proposed two-year transition period, such projects had until March 15, 2022 to install the necessary dispatchability equipment.

In its June 9, 2020 order, FERC accepted MISO’s proposal with little discussion, finding that it was reasonable for MISO to propose its Tariff and GIA revisions without waiting until exigent reliability concerns from non-dispatchable solar penetration.  FERC also rejected the protesting developer’s concerns, noting that already-generating solar facilities with executed GIAs and nearly-completed solar facilities were not similarly situated, and that, moreover, the two-year transition is a reasonable time period to enable nearly-completed solar resources to install the equipment necessary for dispatchability.

A copy of FERC’s order can be found here.

This post originally appeared on the Washington Energy Report blog, hosted by Troutman Sanders, LLP.

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