Regional Resource Assessment (RRA) Feedback Request (20211117)

Xcel Energy appreciates the opportunity to provide feedback regarding the Regional Resource Assessment (RRA).  Please refer to the document sent to stakeholder relations.  Thank you.

WPPI found the Nov 17, 2021 Regional Resource Assessment Workshop very interesting and informative. The assessment was presented clearly and concisely. At this stage, while WPPI’s feedback on the RRA questions posed by MISO is limited, we offer it nonetheless should it be useful.

1. MISO would like input on the scope of the 2022 RRA.

(a.)  What should the technical focus include?

• Are there dimensions, in addition to flexibility, that should be explored during extreme events?

(b.)  How granular should the results be reported/modeled?

• MISO N/C and MISO S (given current limited transfer capability between MISO N/C and MISO S) as well as the MISO footprint
• It would be helpful to see the resource adequacy results for 2030

(c.)   Do you have suggestions for a sensitivity analysis?

• Perhaps, how does an [8] hour vs. a 4 hour battery affect the results
• Especially in the case of the resource adequacy and flexibility assessments, it would be interesting to track how key results change with each annual RRA. How stable are the inputs? How stable are the results? What’s changing, what’s not?

(d.)  Is there anything you would change about the resource assessment process and analysis?

• It would be helpful to report carbon emissions reductions from 2005 (vs. 2021) because 2005 is often used as the baseline for carbon emissions

(e.)  Is there anything you would change about the resource adequacy assessment?

• See (b)

(f.)    Is there anything you would change about the flexibility assessment?

• WPPI agrees it is important to assess the flexibility of the RRA portfolio when there is uncertainty

(g.)  Are there any other areas of the scope that should be addressed that are not currently?

• No feedback at this time

 2. MISO also invites stakeholders to provide any additional feedback about the Regional Resource Assessment.

• WPPI appreciates how MISO framed the RRA (“should not be viewed as a recommendation or plan,” but a way to begin to understand the potential implications of information that is available)
• Results WPPI found especially informative/interesting:

‒         Potential timing of the inflection points suggested by the Renewable Integration Impact Assessment (integration complexity, at 30% renewable energy; appears manageable, at least up to 50%)

‒         How resource adequacy risk by season might change by 2040 (particularly interesting was the potential for a large decrease in summer risk)

‒         What wind and PV solar capacity accreditation might look like in 2040

‒         What PV solar/battery and battery (only) capacity accreditation might look like in 2040

‒         RRA resource mix seems to have adequate flexibility to address variability at system-wide level

America’s Power Comments on MISO’S 2022 RRA
December 10, 2021

America’s Power is pleased to offer the following comments on MISO’s 2022 Regional Resource Assessment (RRA) process, in response to MISO’s request for feedback at the November 17, 2021 RRA Workshop. America’s Power is a national trade association representing the entire value chain of coal-fueled electric power, including coal production, transportation, and electric power generation. We are also members of the Advisory Committee’s Affiliate Sector.

1. The 2021 Regional Resource Assessment states that, "The results should not be viewed as a recommendation or plan for how members achieve publicly announced goals." We recommend that the 2022 RRA process culminate in findings that are actionable for MISO members. Without explicit recommendations about how system concerns that are identified in the RRA process should be addressed—or at least identifying which system concerns need to be addressed—it is not clear that the good work that goes into the RRA analysis will have a meaningful impact.

2. The 2021 RRA uses announced generator retirements, new builds, and state/utility-announced emission reduction plans. In the 2022 RRA, MISO should assess and identify which of these plans have the greatest impact on performance risks in the MISO system, e.g., by causing extreme intraday swings in net load that must be met by ramping resources.

3. Battery storage technology seems to play an important role in RRA models of MISO’s future resource mix. In the 2022 RRA, we recommend MISO consider the potential for the supply of such batteries to be limited due to high international demand, and to model scenarios in which the deployment of battery storage is constrained by such limits.

4. To the extent possible, MISO should consider resource flexibility when projecting resource expansion in the EGEAS model, in order to better address the growing concern of whether sufficient dispatchable resources are available to support intermittent renewable generators.

5. MISO should define and assess zonal and regional resource flexibility needs in order to help ensure that relevant decision makers are aware of how zonal supply levels compare (or could compare) to those needs.

6. In assessing resource attribute needs and other system needs, MISO should consider the ability of resources to withstand extreme weather events and ensure resilience in addition to reliability.

7. Perhaps most importantly, it seems critical that the RRA process include a financial dimension, so that members and stakeholders can 1) understand the cost implications of their announced resource goals to the entire MISO market; and, 2) investigate whether and how MISO market products will compensate the evolving resource mix.

Respectfully submitted,

Michelle Bloodworth
President & CEO
America’s Power

The Environmental Sector appreciates MISO’s establishment of a longer-term resource adequacy assessment with the RRA and for this opportunity to provide input into that process.

First and foremost, we want to express our strong support for the RRA and its importance to maintaining a clear understanding of the transition underway across the MISO system and how MISO and its members must respond to maintain resource adequacy. The RRA is an important complement to near-term resource adequacy efforts including the planning resource auction and the OMS-MISO survey.

We encourage MISO to update the RRA on an annual basis as planned. The landscape can shift significantly and rapidly as conditions change, capital costs drop, new commitments are made, and new policies are adopted. Therefore, an annual timeline for the RRA is appropriate to continue being responsive to the ongoing transition.  

The Environmental Sector also encourages MISO to be more assertive in articulating its information needs and working with relevant entities to gather that information in a regular and timely manner. It is concerning that, in this inaugural RRA, MISO felt the need to hire an external consultant to research utility IRPs, public announcement, state policies, etc. that provide crucial info to MISO as it tries to plan for future conditions. This is information that should be readily available, and we encourage MISO to be proactive and assertive in seeking solutions that provide MISO the information it needs for a holistic understanding of expected changes to the system.

With regards to the scope of the RRA and potential sensitivities to be included in future iterations, we recommend MISO not broaden the scope or add sensitivities unless insights from the initial look at resource adequacy over the planning horizon indicates a need for further study. We generally see the RRA as an annual “gut check” that could lead to further study and stakeholder engagement to address identified issues but should initially be limited in scope.

With regard to the granularity of the RRA, the Environmental Sector believes that the current, system-wide level of granularity is appropriate. Similar to any decision to broaden scope or add sensitivities, whether to progress to a deeper level of granularity should be informed by this initial system-wide assessment. MISO should be diligent in its review of RRA for subregional or zonal trends that warrant stakeholder attention and engagement. This review should be a part of the annual RRA process, but additional study or deeper levels of granularity should be first informed by the system-wide review as opposed to baked into the process without quantitative justification.

Thank you for the opportunity to provide input.

Sam Gomberg on behalf of the Environmental Sector

Great River Energy (GRE) appreciates the emphasis that the Regional Resource Assessment (RRA) Report is high-level, informational, and not meant to represent recommendations for members. GRE believes this framing is important to carry forward to future versions of the report as well.

GRE looks forward to MISO’s increased collaboration with stakeholders for the 2022 RRA Report and supports individual meetings with members early in the process as well as continued collaboration and results review prior to publication of the final report. Specifically, GRE would appreciate increased emphasis on stakeholder review of study assumptions, such as the forecasts and the specifications of the utilities’ systems and goals as represented in the modeling.

If results are provided at a more granular level, GRE would support results at the regional or Local Resource Zone level, rather than at the individual member level.

MISO needs to consider the effects of a wind drought similar to the 39 hour wind drought which occurred on January 29-30, 2020 in its future Regional Resource Assessment.