In the March 10 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were invited to submit feedback on Options for modeling Planned Outages in the LOLE study.
Comments are due by March 24.
AMES, MGE, MPPA, and SMMPA generally support WPPI Energy's feedback.
I'd be happy to discuss.
David Sapper
dsapper@ces-ltd.com
MISO states its intention to assume that outages are perfectly scheduled outside of the peak period and high risk periods. MISO admits this is unrealistic and that MISO does not have the authority to schedule outages in a way that perfectly schedules them outside of the peak/high risk periods. As such, MISO should model outages in a 100% realistic manner. If this results in a higher LRR%, then market participants should respond by moving outages outside of the peak/high risk period. In this case, Planned Outages would be perfectly scheduled outside of the peak/high risk period. Simply put, COMPP encourages MISO to rely on historical behavior and not unnecessarily include unrealistic assumptions in the LOLE to decrease the LRR%.
DTE Electric appreciates the opportunity to provide feedback on options for modeling planned outages in the LOLE Study. We support improving the modeling of planned outages in LOLE as it has a significant impact on PRM. It is a little concerning to see that none of the proposed methodologies appear to accurately capture the volume of planned outages in the winter and summer periods. In the winter all options overstate the volume of planned outages by a significant amount and in the summer all options model 0 GWs for much of the summer whereas the actual volume of planned outages is >5GWs. This raises a few questions:
WPPI appreciates MISO investigation into new planned outage modeling techniques and is encouraged with the multiple options MISO has outlined. In the list of options for flexibility, a 20-30% flexibility appears to be reasonable assumption because this would be a good representative percentage of planned outages that could move if requested by MISO, though we would welcome MISO’s thoughts from its experience in outage coordination as to the appropriate numbers to use here. In regards to using “Max Load” or “90 Percentile”, we believe we have not seen enough details to make an informed decision as to the merits of one approach over the other. At this time, only information we have available to distinguish the merits of either approach is their prospective PRM%. If more information could be made available to help in understanding the benefits of either approach, we would be appreciative.
Lastly, we are curious about how MISO/Astrape derived the 90% and Max levels from the load data. Did MISO use the highest of 30 values for the Max, and the 3rd or 4th highest for the 90% level or alternatively, did MISO synthesize a probability distribution from the 30 load shapes?
The Entergy Operating Companies (EOCs) appreciate the opportunity to provide feedback on the LOLE planned outage methodology.
In the March RASC meeting MISO detailed how the various planned outage methodologies would impact the MISO-wide PRM. The EOCs stress the importance for MISO to further study and make available data showing how the planned outage methodology options will impact the various MISO LRZs. Until this data is made available, the EOCs will not be able to provide fully informed or complete feedback.
Based on the MISO-wide PRM data made available in the RASC, the EOCs believe that the perfectly optimized planned outage methodology is satisfactory. However, if MISO moves to a new methodology, the EOCs believe that LOLE planned outage schedules should be developed using max load profiles because this results in planned outage schedules that generally align with real world planned outage schedules. The amount of flexibility built into the unique LOLE planned outage schedules for the 30 weather years should be supported by a MISO analysis examining the amount of historical planned outages that have been rescheduled on short notice in the past.