Center for Renewable Integration (CRI) teamed with Environmental Law and Policy Center (ELPC) to submit comments opposing MISO’s SATOA filing at FERC. MISO’s proposal sets up an uneven playing field, essentially baring non-transmission owners from even proposing solutions. CRI & ELPC ask FERC to reject MISO’s filing and require the ISO to refile with the following guidance: 1) ensure both transmission owners and non-transmission owners can compete on a level playing field; 2) require the ISO to remove any restrictive language from their tariff that constrains energy storage to a “non transmission alternative” classification; 3) ensure the ISO includes all technologies included in the Federal Power Act as advanced transmission technologies (e.g. energy storage, distributed generation, load control, power flow, load control and others).
Comments can be downloaded here.