In the July 7, 2022 meeting of the Loss of Load Expectation Working Group (LOLEWG), stakeholders were invited to provide comments on the potential sunset of the LOLEWG at the end of 2022.
Comments are due by July 21, 2022.
Consumers Energy appreciates the opportunity to provide comment regarding the Loss of Load Expectation Working Group (LOLEWG) potential sunset at the end of 2022.
While Resource Adequacy topics are discussed in both LOLEWG and RASC forums, the LOLEWG allows time and a more focused stakeholder sub-group to dig deeper into technical discussions and at times some policy issues as they develop while reviewing, seeking clarity and understanding and providing recommendations related to LOLE model inputs, assumptions and analysis.
MISO's offer to add additional workshops as appropriate is not equivalent to having a standing working group to provide a forum for ongoing engagement and working with MISO staff review and provide recommendations in support of the LOLE analysis.
As the analysis inputs and assumptions are modified on an annual basis, it is incumbent upon MISO to retain this forum to enable stakeholders sufficient time and discussion space to review and provide recommendations to MISO on the methodology and input assumptions used to perform the LOLE analysis, especially in light of accelerated changes to the markets and resource fleet, adjustments required to support seasonal and locational Tariff and BPM language per the LOLEWG Charter.
MISO's notes that topics are covered in both LOLEWG and RASC forums in similar amount of detail does not reflect that at least some stakeholders have different stakeholder participation for one or the other forums even though some stakeholder participation overlaps. Consumers Energy often has additional or different subject matter experts attending the more technical and specialized focus of the LOLEWG and other stakeholders have similar additional or different names beyond familiar participants in many RASC meetings.
In short, Consumers Energy supports retention of the LOLEWG as its Charter to review and provide recommendations on the LOLE analysis and potential improvements or changes in these unprecedented times suggests additional focus on the LOLE effort rather than even less.
The Michigan Public Service Commission (Michigan PSC) thanks MISO for the opportunity to provide feedback regarding its proposal to sunset the LOLE Working Group in 2023. The Michigan PSC does not support sunsetting the LOLE Working Group in 2023. Regularly scheduled LOLE Working Group meetings, in addition to RASC meetings, are a highly beneficial opportunity for all stakeholders, including state commissions, to discuss and understand the assumptions and study methods used in MISO’s LOLE analysis.
The LOLEWG Charter states that the "primary purpose of the LOLEWG is to work with MISO staff to perform Loss of Load Expectation (LOLE) analysis that calculates the congestion free Planning Reserve Margin (PRM) requirements as defined in the Module E-1 of the Tariff." Additionally, the Charter requires the LOLEWG to "review and provide recommendations" on the LOLE and CIL/CEL methodology and assumptions. These tasks of the LOLEWG continue to take place in preparation for each Planning Year and will increase in scope and magnitude upon FERC approval of the proposed seasonal RA construct and SAC methodology. WEC Energy Group believes that the SAC methodology, coupled with potential accreditation changes for intermittent resources, will increase the importance of the LOLEWG's review of the LOLE methodology and input assumptions.
We expect the LOLEWG to identify enhancements and recommendations to further align the LOLE study with the seasonal construct and SAC methodology. We do not support the sunset of the LOLEWG at this critical period in the evolution of MISO's RA construct.
WPPI Energy does not support sunset of the LOLEWG at this time.
MISO’s presentation cites several grounds for sunset, including:
We don’t think it’s true that policy or technical discussions have been duplicative between the groups to a significant extent. We note that, while there may be significant overlap between participants in the two groups, LOLEWG typically has much smaller participation, so that consideration of stakeholder overlap actually supports maintaining LOLEWG as a separate group. The claim that LOLEWG sunset will support continued process improvement is one that we find too vague to meaningfully assess.
We note that the LOLEWG has, as detailed in the charter, responsibility for a very specific set of topics—the periodic LOLE analysis, CIL/CEL Analysis, and Wind & Solar Capacity Credit calculation. MISO presumably intends that these be incorporated within the direct purview of the RASC. This appears unrealistic to us. RASC has had very busy meetings throughout its recent history, limiting its ability to take on additional detailed topics. Moreover, we believe it has been necessary to curtail detailed discussion at RASC to accommodate all presentations on the agenda, which makes it hard for us to have confidence that we can make needed progress on detailed technical topics like improvements to CIL/CEL analysis. If anything, we would like to see more discussion moved from RASC to LOLEWG rather than the reverse.
It is Hoosier Energy’s strong belief that the Loss of Load Expectation Working Group (LOLEWG) should remain active. The LOLEWG provides a forum allowing for a more technical assessment and thorough discussion of the assumptions underlying the LOLE study, which will become even more important if/when the Seasonal Accredited Capacity (SAC) filing is approved. Recent, and likely future, RASC meetings have had full agendas that will not allow for the LOLE assumptions to receive the same attention and discussion that they currently do. While MISO proposes replacing the LOLEWG meetings with workshops when necessary, it would be more valuable for stakeholders to continue with regularly scheduled meetings that provide certainty as to scheduling. Finally, if MISO ultimately decides to sunset the LOLEWG, it should allow the working group to remain active for at least one year after the SAC filing is approved to assess MISO’s incorporation of seasonal assumptions into the LOLE study.
The OMS Resources Work Group (OMS RWG) appreciates that MISO wants to conduct its meetings in the most efficient manner and avoid duplicating policy and technical discussions within multiple forums. However, the OMS RWG opposes sunsetting the Loss of Load Expectation Working Group (LOLEWG) at this time. As we implement changes to the Resource Adequacy Construct and work to align MISO’s annual LOLE study with these changes, the work of the LOLEWG will continue to be extremely important. It is essential, for both transparency and thorough stakeholder review, that a focused forum remain for this topic.
This is OMS work group feedback and does not represent a position of the OMS Board.
The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback on MISO’s proposal to sunset the LOLEWG.
The EOCs do not support sunsetting the LOLEWG because the LOLEWG provides a good forum for stakeholders to have technical focused discussions with MISO staff which are more difficult to accomplish in RASC meetings. Additionally, the number of agenda items being covered in the RASC is already high so it would be difficult for MISO to accommodate LOLEWG related work items into the RASC agenda.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
Xcel Energy appreciates the opportunity to provide feedback regarding MISO’s proposal to sunset the LOLEWG at the end of 2022. We feel that dismantling the LOLEWG is immature at this point due to the potential revisions needed in the LOLE analysis due to the following:
MISO stated in their April 8, 2022, response to FERC’s Deficiency Letter in the Seasonal and Accreditation Requirements for the MISO Resource Adequacy Construct Filing that “…MISO is evaluating further enhancements to LOLE modeling to better align reserve requirements and accreditation.” These type of discussions will need to occur in a forum that has the time and stakeholder expertise to review and evaluate the proposals.
The RASC simply does not have the time within the next year to hold these discussions within our normally scheduled meetings. Stakeholders have already requested two workshops to add to the RASC schedule to accommodate the discussions needed to develop a conceptual design for non-thermal accreditation. In addition, the RASC will soon be devoting time to PRA improvements and incorporating resource attributes into resource adequacy. The LOLEWG is the forum to have these technical, detailed discussions with stakeholders so we believe strongly that the LOLEWG needs to be maintained as a separate working group for at least another year.
DTE Electric prefers to keep the LOLEWG meetings to allow for in-depth discussion on technical modeling. With the length of the recent RASC meetings, we do not feel that adding further discussion to the RASC will be beneficial to the stakeholders. While there may be some overlap, we would like to keep the LOLEWG and the RASC separate.
Michigan Public Power Agency (MPPA) recommends against sunsetting the LOLE Working Group, as it serves as a critical forum for analytical/technical issues related to Resource Adequacy (RA). Sunsetting the LOLE WG perplexes MPPA given MISO's Reliabiliity Imperative and the current RA situation in MISO Central and North. Were MISO to eventually adopt a different approach/measures to the PRA foundational framework, sunsetting LOLE WG and replacing it with something like an "RA Analysis WG" would make sense at that time.