We recommend that LMRs and emergency-only resources receive PRA capacity credit if they are expected to be reasonably available in an emergency. This means their time to deployment (notification plus start-up time/shut-down time) should be less than a benchmark to be determined by MISO (e.g., one or two hours). Establishing such a benchmark should be based on MISO historic experience regarding how long in advance of its capacity shortages MISO has typically declared a Maximum Generation Event to enable access to the emergency resources.
As a secondary associated issue, we also recommend that MISO develop a reasonable methodology for quantifying the capacity credit for emergency-only resources in the PRA. Such a methodology should consider factors that reduce the expected availability of the resource, including the resources’ seasonal availability, variation in available curtailment quantity, and historical performance.
The objective of these changes should be to qualify the LMRs at levels that would accurately reflect their expected availability during emergency conditions. This is comparable in principle with MISO’s UCAP methodology for its generators.