In the April 14 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were invited to submit feedback on the new planned outage method discussed for the Loss of Load Expectation (LOLE) study.
Comments are due by April 28.
The LOLE scheduled outage methodology should have alignment to the approach used in the forthcoming changes in the forthcoming RAN Reliability Requirements
The LOLE uses a net load value which includes the impact of all MISO renewable generation. There is uncertainty in the energy dispatch capability of wind as shown by the 6,000 MW decrease on 10/16/2020. With this data being netted with MISO system load, it is not possible to evaluate the impact of this uncertainty in the LOLE calculations. The uncertainty of the wind dispatch needs to be distinctly quantified in order to make sure the overall LOLE calculation is taking into account the uncertainty.
The Entergy Operating Companies (EOCs) appreciate the opportunity to provide feedback on the LOLE planned outage methodology.
The Entergy Operating Companies believe the proposed Flexible Outage methodology generally is reasonable but have concerns that the impacts of the change in methodologies to the Local Resource Zones in MISO South are more significant than to other zones in MISO. The EOCs ask that MISO provide more information regarding the reasons that Zones 9 and 10 have a larger increase in LRR% relative to the other zones in MISO and consider whether these outsized impacts warrant any adjustments to the methodology or other steps to mitigate potential harm to customers in these zones.
DTE Electric appreciates the opportunity to provide feedback on options for modeling planned outages in the LOLE Study. To reiterate our concerns from the previous feedback request, 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. MISO’s response to this feedback was “The new planned outage modeling improves alignment between modeled and actual outages” but the currently proposed methodology is less reflective of the volume of summer outages when compared to the realistic outage methodology. Is MISO concerned that each of the planned outage methodologies understate the typical volume of planned outages that would be expected during the summer?
A. Regarding the development of the "flexible outage scheduling" method for modeling how scheduled outages would affect available resources for reserve margin planning purposes, Energy Michigan sees that MISO has taken a thorough look at the situation and has come up with a creative and reasonable method supported by evidence. Our compliments to the modeling group.
B. Energy MI notes again that even small changes in reserve margin modeling can have very large financial effects, and consequently ought to be discussed in depth and justified by stakeholders before implementing. This is different from the merits of the analytical methods.
For example, the "flexible outage" method adds about 2% to the Zone 7 PRM and thus 2% to the Zone 7 LCR. That's about 400 MW of additional investment in capacity in the longer term. At $600 per kW, the additional investment is about $240 million. $240 M consequence of a small tweak in modeling scheduled outages.
C. As Energy MI has explained previously, there are errors in the way the LCR is determined -- primarily from the way the CIL is used and from the theory that under the 1-in-10 standard for the region, it is necessary that each zone must meet a 1-in-10 standard individually and independently. The entire concept of imposing additional LOL obligations on individual zones has never been thoroughly vetted. It was added in as a plausible expansion of the regional 1-in-10 concept, and as long as it had no practical effect, no one really cared. But with Zone 7 hitting CONE in the current Planning Year, it is time to take a look.
Energy MI sees the zonal LCR requirements as being in error and sees the assignment of a 1-in-10 obligation on independent individual zones as an imposition of a reliability standard greater than the 1-in-10 for the region.
We want the relationship between LRR, CIL, and LCR corrected. And we are happy to help with the vetting of the zonal reliability standards.
Minnesota Power's recommendation is to move forward with the "Flexible" planned outage modeling option for future LOLE studies.
Thanks for the opportunity to provide feedback.
Given MISO’s experience that 20% of outages are flexible, AES Indiana supports MISO’s proposal to utilize flexible outage planning in its LOLE study.