In the September 1 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were invited to review proposed edits to Business Practice Manual (BPM) 011 Resource Adequacy and to provide feedback.
Comments are due by September 15.
DTE appreciates the opportunity to provide feedback on the Annual BPM-011 Review. In Section 4.1 of the draft BPM 11 MISO has added the language, “In addition, historical data related to outages and derates on specific resources may be reviewed by the Market Participants, MISO, or the Independent Market Monitor to determine an appropriate level of UCAP for those resources.” This addition seems unnecessary because the XEFORd of a resource already accounts for historical data related to forced outages and forced derates in the UCAP calculation. To further lower a UCAP value would essentially be double counting the impact of historical forced outages to a unit’s accreditation. DTE Electric is uncertain if this line was added to give MISO and the IMM the ability to use historic planned outages to modify the calculated UCAP of a resource. If that is the case, it would be a significant departure from the current approved accreditation rules and DTE Electric would not support such a change in methodology to determine UCAP. DTE Electric would prefer this statement be removed from the BPM until it is clarified what is intended by the statement. If it is a change in methodology (whether double counting forced outages or including planned outages), it should be first vetted through the stakeholder process before filing with FERC for approval.
In Section 6.4.1, this statement is confusing and potentially conflicts with other portions of BPM-011:
"However, should a BTMG resource indicate availability in the DSRI at any time in a Planning Year, it is considered available in the event of an Emergency and may receive Scheduling Instructions."
Specifically this new statement seems to conflict with Section 4.2.7:
"...the Scheduling Instructions (dispatch directives) and ultimately performance and availability review will utilize the information in the DSRI at the time the Scheduling Instruction is issued" and "If an Emergency is declared by MISO that requires LMR deployment, MISO will issue Scheduling Instructions in the DSRI using the LMR availability information (“MWs available for MISO” and “Self Scheduled MWs”) provided by MPs."