In the August 4 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were asked to provide feedback on proposed draft BPM language for LBA / LSE Review of ARC LMR registrations.
Comments are due by August 20.
As stated verbally during the August 4th RASC, the Michigan PSC Staff supports standardizing the review process for ARC LMR registrations. The Michigan PSC Staff also supports the proposed review process on Slides 6-7, but would encourage MISO to provide additional clarity on the process when a registration is rejected. The Michigan PSC Staff would also encourage MISO to codify the RERRA’s role in approving ARC LMR registrations, to the extent that it not written elsewhere.
If a registration is rejected by the LBA or LSE, the proposed 10 day review clock should begin anew to avoid undue burdens on each entity involved. This language should be codified in the BPM or tariff for clarity. The Michigan PSC Staff would add the following to the language on Slide 7 (bold italics):
“If during the registration the LBA or LSE is identified to be incorrect the registration will be rejected, and the MP can submit a new registration when they have identified the correct LBA or LSE. This new submission will restart the 10 day LBA and LSE review period.”
To the extent that language regarding the RERRA role in approving ARC LMR registrations is appropriate here, the Michigan PSC Staff would support language similar to that included in BPM 26. To the extent BPM 26 does not explicitly detail the RERRA review process for LMRs, and only details the RERRA’s role in approving ARC DRR and ARC EDR registrations, similar language regarding LMRs should be added to BPM 11.
Thank you for the opportunity to submit feedback.
Consumers Energy appreciates the opportunity to provide feedback regarding the LBA/LSE Review of ARC LMR Registration BPM Language (RASC-2021-1).
Consumers supports MISO's draft BPM language for LBA/LSE Review of ARC LMR registrations. We have no proposed changes or additional feedback at this time.
TO: MISO RESOURCE ADEQUACY SUBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: STANDARDIZING LBA & LSE REVIEW OF ARC LMR REGISTRATIONS
DATE: AUGUST 20, 2021
In response to MISO’s feedback request related to standardizing LBA & LSE review of Aggregator of Retail Customers (ARCs) Load Modifying Resources (LMRs) registrations as presented in the August 4, 2021 RASC meeting, the Entergy Operating Companies ("EOCs" or “Entergy”)[1] offer the following comments.
The EOCs appreciate MISO’s effort to standardize the ARC LMR registration process and the information that is required. While it appears that most of the following registration information is represented in the appendix section of MISO’s presentation (pg 12-13), it should also be included in the proposed BPM-11 language to provide clarity: ARC name, resource type, effective date, termination date, Load Zone CPNode name, Measurement and Verification methodology associated with provided maximum load reduction capability, RERRA name, monthly availability and whether the demand reduction is a BTMG. Of note, monthly availability and whether the demand reduction is a BTMG does not seem to be covered in MISO’s proposal and should be.
Regarding the need of an LSE/LBA to know whether the ARC registration is designated as a BTMG resource or a Demand Resource, BTMG resources require deliverability whereas Demand Resources do not. Under the current structure, MISO relies on an ARC’s word that they have met this deliverability requirement without letting the LSEs and LBAs know that the resource is a BTMG when performing the ARC registration review. In these tariff revisions, MISO should therefore impose a clear requirement that the LSEs and LBAs be informed of whether the BTMG is deliverable and allow them to confirm that the resource is indeed deliverable.
The LSE and/or LBA should also have the option to request background information related to the demand reduction capabilities of the customers comprising the LMR (i.e., actions taken by the customer to reduce load versus normal changes in load associated with operational profile).
We agree that the determination and standardization of the registered capacity of the LMR should be consistent between the MECT and the LBA/LSE. We further agree that the maximum level of participation should not be greater the load of the asset as evaluated by the LBA or LSE.
The proposed ten-day review by the LBA and LSE seems overly aggressive. The EOCs think that the LBA and LSE should have 30 days to review the ARC LMR application.
In addition to the proposed changes, for purposes of measurement of demand response resource performance and ARC settlements, Entergy strongly suggests that MISO require the ARC to use of Electric Distribution Company (EDC) metering where advanced metering infrastructure (AMI) is in place. As MISO is aware, Entergy’s ARC experience has been that there typically is a 50% or greater discrepancy between the ARC’s measurement system and the Entergy Operating Company meters. This obviously is significant and there is not a good reason to allow such discrepancies to occur. The retail demand response resources in an ARC are already metered by the EDC. With AMI in place, the metering can accommodate MISO’s real time five-minute dispatch and settlement. Moreover, the problems with the use of customer baselines has been identified by the MISO’s Independent Market Monitor (IMM). The IMM, in its most recent State of the Market Report, noted that:
It is important, therefore, to ensure that real-time markets produce efficient prices when DR resources are deployed and to ensure that the contributions of these resources are measured accurately and compensated fairly. MISO should re-evaluate its DRR measurement and verification provisions to address inefficiencies and eliminate gaming opportunities before DRR contributions rise. MISO 2020 SOM Report at p. 107.
Use of EDC AMI would eliminate performance and settlement disputes involving meter data and eliminate the possibility of an ARC getting paid for demand response measured against a customer baseline but which, in fact, the ARC did not provide.
MISO also should provide clear language regarding LSE review of ARC Settlements. While there is language in Attachment TT that clearly provides for LSE review of ARC settlements (Sections 4.3 and 4.4), it has been the EOCs’ experience that when raising reasonable and fact driven objections to an ARC settlement, MISO has relied on BPM language to inform the LSEs that MISO will not evaluate their objections and will instead require the parties to go to ADR. MISO’s explanation of this approach was that BPM-005 § 5.1 refers to disagreements between individual MPs not being covered disputes. The EOCs strongly disagree with MISO’s approach of deferring to an exception in the BPM rather than clear language in the Tariff Attachment TT § 4.3 and § 4.4 providing for the LSEs’ authority to review and approve or deny settlements and the opportunity for the ARC to resubmit the settlement and the LSE to provide additional review afterwards. There is also additional language in § 38.6.D stating that “the Transmission Provider shall review the participation of an ARC in the Energy and Operating Reserve Market when the ARC’s settlements are successfully disputed more than ten percent (10%) of the time by a relevant LSE.” The LSEs role in reviewing ARC settlements is clearly established in the Tariff, but MISO’s interpretation of the BPM language suggests that the Tariff language should be made more clear and directly address MISO’s interpretation of BPM-005 § 5.1 relative to Attachment TT. Section 5.1 of BPM-005 also states that a dispute that MISO’s Market Settlements Department can address includes “[s]tatement disputes cover any calculation, determinant data, or process issues regarding the MP’s Market Settlement Statements. . . .” (emphasis added). Meter data is “determinant data” and disputes over meter data should be handled by MISO’s Market Settlements group. Otherwise, the current process of LSE review involves significant redundancy if MISO is going to rely, by default, on ADR to resolve the dispute. The ADR process can be cumbersome and expensive relative to the amount of MW and dollars under consideration. Ultimately, reliance upon ADR to address these circumstances is unreasonable and inconsistent with maintaining the integrity of market settlements.
The EOCs appreciate the opportunity to provide input.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
DTE appreciates the opportunity to provide feedback on LBA/LSE Review of ARC LMR Registration BPM Language. DTE seeks additional clarity on a couple items within the draft BPM language:
- MISO appears to have broken up “end use customer account number” into end use customer and account number as separate items. Please clarify if this was intentional or please update language to reflect “end use customer account number”.
- The BPM states that “If during the registration the LBA or LSE is identified to be incorrect the registration will be rejected, and the MP can submit a new registration when they have identified the correct LBA or LSE” Does this new submittal restart the timeline for review back to 10 days?
- “The assets load should be calculated as average load of the asset up to the last 3 Annual (or Seasonal when applicable) MISO peaks.” Please clarify if this average load is analogous to the peak load contribution of the asset.
Voltus generally supports the effort undertaken by MISO to standardize how LBAs and LSEs review LMR registration materials. We agree with the list provided in slide 4 of the presentation to the August 4 RASC delineating which data is provided for the LBA and LSE to validate and what data is provided for informational purposes.
The proposal to base maximum enrollment amounts on an asset’s average load during the last three MISO peaks is appealing in its simplicity. However, in some cases, historical data is not an accurate representation of future projected demand. For example, a load may have been shut down for maintenance during one or more of MISO’s prior peaks, or a facility’s operations may have materially changed, altering the site’s electricity demand. Per section 69A.3.3 of the MISO Tariff, “The amount of ZRCs from Demand Resources and BTMG has to be consistent with the expected reduction in demand at the time of the Transmission Provider’s expected coincident Peak”. Therefore, where historical load data is not “consistent with the expected reduction in demand” during the succeeding Planning Year, Market Participants who register LMRs should be permitted to present an alternative method of projecting demand and submit an attestation stating why the proposed method is more accurate.
There is extensive precedent that could be used to guide how Market Participants can adjust historical load values to project future demand. Business Practice Manual 11 section 3.2.2, for example, states that peak demand forecasts “shall be based upon considerations including, but not limited to, average historical weather conditions, economic conditions, and expected Load changes (addition or subtraction of demand).” MISO’s Peak Forecasting Methodology Whitepaper (available at https://cdn.misoenergy.org/Peak%20Forecasting%20Methodology%20Review%20Whitepaper173766.pdf) provides an overview of several acceptable and unacceptable methods of accounting for these considerations.
Voltus supports the effort to reduce processing time for LMR registrations discussed on slide 12 of the slides presented at the August 4 RASC. Where LBA or LSE review uncovers easily-fixed issues, however, it would not be expedient to restart the process. For example, if an LSE objects to a registration only on the grounds that a meter ID has been updated, and the LSE provides the updated meter number, it should be possible for the registration to go back into “revising” status, for the MP to update the meter data to reflect LSE feedback, and for the registration to then be approved. Similarly, if an LBA or LSE approves some of the particular locations in a resource and rejects others, it should be possible for the MP to revise the registration to remove the rejected locations and to proceed to approval with the remaining, approved locations. The LBA or LSE should not need to review a registration again when they already approved it but for issues that have been addressed. Ideally, the LBA or LSE could formally grant “conditional approval” pending specified revisions.
We will submit a redline to the proposed BPM language, reflecting the comments above, over email. Our redline also seeks to clarify the difference between LMR resources, which may comprise one or many locations/assets, and particular assets. LBA and LSE review should be at the asset level.