RASC: Hybrid Accreditation Proposal (RASC010) (20210512)

Clean Grid Alliance thanks MISO for the presentation at the May RASC meeting on MISO’s updated proposal for Hybrid Accreditation, as well as the opportunity to provide further input on this proposal.  We very much appreciate that MISO has taken stakeholder input into consideration in the evolution of this proposal, and we believe that the current proposal will better approximate the capacity contribution these resources offer the MISO market and at the same time offers the opportunity to learn as MISO and stakeholders get more experience with hybrid resources and the types of arrangements that are made at Surplus Interconnection sites, which can include a hybrid arrangement between the resource owners.

We reiterate our support for MISO’s two-phased approach to hybrid accreditation which offers a simple additive approach to capacity based on fleet wide average capacity contributions until a hybrid resource has historic operational data.  In the second phase, the accreditation will be based on the actual output or availability during peak hours.   We support MISO’s proposed definition of a Hybrid Resource for use in its Tariff, and the proposed tariff changes intended to implement this proposal.

We offer the following input on issues that MISO has indicated will be addressed in the BPM.

• Specifics of assessing availability on peak hours:
  When assessing availability, any renewable resource output should be considered with the elimination of any reduction in output that results from curtailment (i.e., adding back in any curtailed energy).  Availability of an energy storage resource (ESR) that may not be delivering power to the grid during an identified peak hour should be based on whether or not the ESR is on an outage.

• Deliverability of hybrids in Phase 2:
  Phase 2 plans to accredit a hybrid resource based on its actual output or availability.  This should result in a single capacity contribution value.  Deliverability should consider whether the capacity contribution value for the hybrid resource is at or below the total firm transmission service for the resources at that point of interconnection in the form of NRIS service, ERIS service plus a firm transmission reservice request, or NITS service.

• Exact number of peak days and peak load hours to use:
  We do not currently have a proposed number of peak hours or peak days that should be used to determine hybrid accreditation.  But 8 hours, as is used to accredit wind resources, is an insufficient number of hours to evaluate the capacity contribution of a resource.  In fact, we urge MISO to expand the number of peak hours used to accredit wind resource capacity contribution.  It may be better for MISO to consider not the number of peak hours in a year, but any peak hours that are above a certain threshold, or during which the reserve margin drops to a certain level.

• Surplus pathway to hybrid:
  Any resources at a Surplus Interconnection that have contracts that allow the output of the two or more resources to be optimized should have the option to have their accreditation evaluated as a hybrid resource.

We also appreciate that MISO has clarified that resources behind a Surplus Interconnection may operate as a hybrid resource, and thus may qualify to have their accreditation evaluated as a hybrid resource.  In the case that resources at a Surplus Interconnection are not treated as a hybrid and will be evaluated separately, those parties should be able to decide how to divide any firm transmission shared by the resources as that firm transmission service relates to deliverability and the determination of each resource’s accreditation.

MidAmerican appreciates MISO’s efforts and supports further clarification on the accreditation of hybrid resources. MidAmerican encourages MISO to take additional measures to incorporate availability in the accreditation process to ensure hybrid resources are not disproportionately penalized for not dispatching during peak hours. MidAmerican supports other stakeholder feedback that accreditation should be based upon service and delivery at the POI, unrelated to the origin of the generator being hybrid or surplus.

Xcel Energy appreciates the opportunity to provide feedback regarding the hybrid accreditation proposal.  We are supportive of the Tariff revisions in Module E-1 as they adequately  represent MISO's last proposal for hybrid accreditation. 

Proposed Revisions for Definitions in Module A.  We would recommend that MISO define a Hybrid Resource and then use that explicitly, instead of repeating “including any combination of the above eligible resource types...” in the other definitions.  In addition, it appears that MISO is including DRR-Type I and DRR-Type II as eligible resources for inclusion in a hybrid resource under the definition of “Capacity Resources” and “Resources,” but the definition of a Hybrid Resource includes only “generating devices.”  Which is correct?