April 23, 2021

ESA Files Rebuttal to MISO’s Defense to its Request to Delay Order 841 Implementation

ESA jointly submitted comments with the American Clean Power Association, Clean Grid Alliance, Advanced Energy Economy, the Southern Renewable Energy Association, and the Solar Energy Industry Association (collectively, the “Clean Energy Coalition”) in response to MISO’s answer to protests (docket no. ER19-465-004) against the RTO’s request for a three-year extension on its implementation of Order 841.
In our comments we explain that MISO failed to refute information in the Clean Energy Coalition’s Protest on 3/19 detailing the detrimental impact to the energy storage industry if FERC grants MISO’s extension request from June 6, 2022 to March 1, 2025. In MISO’s response to the protests, it claims that energy storage resources can currently participate in MISO’s capacity market in the Stored Energy Resources – II (“SER-II”) program. However, zero storage resources are currently participating in MISO’s capacity market because this program lacks parameter inputs that are required for ESR to participate effectively, and thus, we argue that there are no options available for the 7500 MWs of standalone and hybrid ESR that have entered the interconnection process. Additionally, MISO claims that the delay to implement its software system will result in $300 million in benefits to the region. The Clean Energy Coalition points out that this figure is unsupported and that it also pales in comparison to the approximately $7.5 billion investment in storage projects now in the queue and planned for operation before 2025.
For these reasons, the Clean Energy Coalition urges FERC to reject MISO’s Order 841 extension request.

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