At present, there is no clear articulation of the process by which Energy Efficiency (EE) measures are included in the Demand Side of the MISO Planning Resource Auction (PRA). MISO’s current load forecasting process requires LSEs and EDCs to submit Coincident Peak Demand and related data to MISO for that information’s integration into the Resource Adequacy Construct and are then used to establish a demand curve for the PRA.
For the last two PRAs, material decreases in Coincident Peak Demand forecasts were attributed to additional EE installations without a description of the nature or timing of those EE installations. Module E-1 provides ”Such [coincident peak load] forecasts shall include Demand that would have occurred but for the existence of Energy Efficiency Resources that have been in operation less than four (4) years.” This means that EE measures installed within the previous 4 years should not function to decrease a Coincident Peak Demand forecast submitted to MISO.
In addition, “An EE Resource can annually qualify as a Planning Resource for ZRCs for up to four (4) Planning Years immediately following the EE Resource's initial qualification provided that the energy efficiency measures are fully implemented prior to each Planning Year.” MISO Module E-1, 69A.3.2.
EE resources offered into the PRA as supply are subject to the Measurement and Verification (M&V) processes in the Resource Adequacy BPM and Attachment UU.
A gap exists here where EE measures that fall short of meeting the standards for qualifying as ZRCs, are less than 4 years old, are not otherwise verified by MISO could be included in Coincident Peak Demand Forecasts. By rolling certain EE measures into the load forecast, the EE are able to offset demand and also avoid verification. To avoid potentially negative reliability impacts, an opportunity exists for MISO to articulate the process for including EE in Coincident Peak Forecasts, to validate the quality of such EE measures, and to improve the transparency associated with the conversion of supply-side EE to demand-side EE.
Issue merged with RASC-2019-7 Planning Resource Auction Load Forecast Verification and Transparency.