LOLEWG: Out Year CIL CEL Study Scope

ITC Holdings Corp (ITC) appreciates the opportunity to submit feedback concerning which LRZs should be included in the Out-Year CIL/CEL analysis.  MISO’s stakeholder meeting material from the most recent LOLE meeting indicates that LRZ 7 does not meet the BPM criteria for inclusion in an out-year CIL study based on last year’s PY ‘21/’22 results.  However, our internal analysis indicates that LRZ 7 may fail to meet relevant PRA requirements in the upcoming auction.  There have been significant thermal retirements in LRZ7 and Tier 1 & Tier 2 source zones which, combined with existing transmission constraints, have both reduced LRZ 7 by over 1 GW and put downward pressure on internal ZRCs.  Even If LRZ 7 does not clear at CONE in this upcoming auction, we think there is a high likelihood that it will be by a small enough margin to warrant inclusion in next year’s Out-Year CIL analysis

As proactive planners, we respectfully request that MISO staff include a CIL analysis for LRZ 7 in this year’s study.  In addition, we would ask that staff provide the total installed MWs by fuel type that was included in the study for all LRZs considered.  We recognize that announced generation retirement and additions change often and want to make sure our internal planning assumptions align as best as possible with those MISO uses.

Thank you for considering this request.

Madison Gas and Electric (MGE) requests LRZ2 CIL be included in the next out-year zonal transfer capability analysis.  We are concerned with the continued volatility of zone 2's CIL as well as the troubling decrease in CIL for PY 2022-2023.  Such volatility and such precipitous drop in annual CIL hampers our ability to properly prepare for resource adequacy, both in the short-term and in the long-term.  We are left with few options other than to overbuild / over-procure capacity - hardly a "market" efficient approach for our customers.

WEC Energy Group recommends inclusion of the out-year CIL for LRZ2 because of the notable decline in CIL between PY21 and PY22.

Members of the LSE Coalition recommend that MISO estimate out-year CIL and CEL values for Zones 1, 2, 3, and 7, at least.

Thanks,

David

dsapper@ces-ltd.com

WPPI notes that the LRZ2 CIL as determined for PY22 is by far the lowest of the MISO LRZs, and is within a range in which binding in the PRA is plausible.  Accordingly, we believe out-year analysis is merited, and we would request that LRZ2 CIL be included in the next out-year zonal transfer capability analysis.

Due to the volatility in the year-over-year CIL and impact on clearing prices experienced in LRZ 7, Wolverine supports the identification of out-year CILs for LRZ 7.

The Michigan Public Service Commission Staff (Michigan PSC Staff) thanks MISO for allowing us to submit comments on whether additional Local Resource Zones (LRZs) should be added to the CIL/CEL Out-Year analysis. LRZs 2, 6 and 7 should be included in your out-year CIL and CEL analysis since your current year analysis as described at the October 5^th  LOLEWG meeting, 2022-2023 PY CIL-CEL Results Presentation.  Referencing Slide 6 of the presentation, LRZs 2, 6 and 7 all had dramatic decreases of 47%, 23% and 23% from the previous years CIL values.  Based upon these dramatic variations in the CIL values from one year, those three LRZs should be included in the Out-Year CIL/CEL analysis.