Stakeholder feedback is requested on a proposed change to BPM-011 Resource Adequacy shared with the Resource Adequacy Subcommittee (RASC) on November 3:
Section 4.2.9.1: Consider applying 3-year average to all Demand Response (DR) registrations as opposed to only those submitted by an Aggregator of Retail Choice (ARC): The assets’ load should be calculated as the average load of the assets up to the last three Annual (or Seasonal when applicable) MISO system peak hours. One or two years of load data may be used if the full three years is not available.
See detailed from pages 7 and 8 of the attached liaison report.
Consumers Energy appreciates the opportunity to provide feedback regarding MISO's proposed change to BPM-011 regarding application of a 3-year average to all DR registrations as opposed to only those submitted by an ARC.
CE supports MISO's proposed change to BPM-011 language to apply up to 3 years of historical load data as available for all DR registrations regardless of Market Participant or to provide an explanation to demonstrate why historical average peak load is not representative of expected future peak load as applicable.
DTE fundamentally agrees that there should be alignment on LMR accreditation, however we feel the proposed change is too significant to be approved as part of the BPM process. DTE would like to discuss this topic further before supporting the proposed change.
Voltus approves of the proposed change to make LMR accreditation equitable regardless of the Market Participant registering the LMR resource. LMR is, as of now, designed to address system peak needs. As such, it is logical to align accreditation with expected load during system peak conditions. LMRs provide the same grid service regardless of who registers them, and therefore must face the same governance. Applying different rules for the same service to different Market Participants would be undue discrimination.
Thank you for the opportunity to comment. Note this comment is not actually on behalf of a sector, but there was a glitch with the submission portal that required the "sector" field be filled in.
Emily Orvis
Director of Energy Markets
Voltus
emily@voltus.co