During the November 4, 2021 Market Subcommittee (MSC) meeting, MISO discussed system limitation for clearing and deploying offline Supplemental and offline Short-Term Reserves on Stored Energy Resources Type II(SER II) and Demand Response Resources Type II (DRR II) and deploying offline STR on Electric Storage Resources (ESR). MISO requests feedback on the below issues:
1. Proposed FERC filing (Tariff change and/or waiver) to address MISO systems’ inability to clear SER -II to provide offline STR and offline Supplemental
2. Proposal to focus on addressing problem with ESR provision of offline Short-Term Reserve, which cannot be enabled by June 6, 2022 ESR implementation
Please provide feedback by November 18.
WPPI offers the following feedback on the two issues posed by MISO re Stored Energy Resource - Type II, Demand Response Resources – Type II, and Electric Storage Resources and offline reserves:
1. Proposed FERC filing (Tariff change and/or waiver) to address MISO systems’ inability to clear SER -II to provide offline STR and offline Supplemental
As WPPI understand the issue, if per the currently implemented provisions of MISO’s Tariff, SER-II and DRR-II should be able to provide offline Supplemental Reserves then, in order to be in compliance with its Tariff, it seems MISO must make a FERC filing to address MISO systems’ inability to clear SER-II and DRR-II to provide offline Supplemental Reserves. Also, while MISO expects to resolve the issues with clearing DRR-II to provide offline reserves (both offline Supplemental and offline Short-Term Reserves) by the STR implementation date (12/7/2021), the issues are expected to remain in the case of SER-II and, therefore, it seems MISO must make a FERC filing by the STR implementation date in order to address MISO’s systems’ inability to clear SER-II to provide offline STR.
2. Proposal to focus on addressing problem with ESR provision of offline Short-Term Reserve, which cannot be enabled by June 6, 2022 ESR implementation
WPPI supports MISO’s proposal to focus on enabling ESR (and not put effort toward enabling SER-II) to provide offline STR, for a couple of reasons:
(a) The ESR resource type is expected to replace the SER-II resource type.
(b) It doesn’t it appear it will be any easier to enable SER-II to provide offline STR.
Note: It doesn’t appear the tariff posted on MISO’s website includes the Electric Storage Resource provisions.
MEMORANDUM
TO: MISO MARKET SUKBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: SER-II & ESR OFFLINE SHORT TERM RESERVE PRODUCT PARTICIPATION
DATE: NOVEMBER 18, 2021
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the November 4, 2021 MISO Market Subcommittee meeting concerning Stored Energy Resource - Type II (SER-II) and Electric Storage Resources (ESRs) inability to be cleared and deployed in the MISO Energy Market due to MISO system limitations.
The EOCs would agree with MISO, that due to the limited financial impact to the MISO Energy Market, that rather than building a new SER-II unit type to address this issue, it should be solved as a part of the coming ESR resource type. While the EOCs understand that the initial roll out of the ESR resource type will not include the fix, MISO should try to correct this as soon as possible.
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.