During the December 1, 2022, Markets Subcommittee (MSC) meeting, MISO discussed solutions to refine effectiveness and pricing signals of the Ramp Capability Product (RCP). MISO is requesting feedback on the following questions:
Please provide feedback by January 5.
Xcel Energy supports disabling DIR for RCP Up as a temporary solution until MISO develops reserve procurement constraints to reduce the RCP Up clearing of stranded capacity. We understand that there were a small number of intervals in 2022 that would have cleared RCP Down at a price greater than zero, so setting the RCP Down Demand Curve to $0/MWh is reasonable at this time. However, we recommend that MISO report on the number of intervals that would have been short RCP Down on a periodic basis at the MSC and develop a threshold to determine when this action may need to be reversed. We do support separating the eligibility for RCP Up and RCP Down and believe this should be extended to other ancillary services as well.
AMP supports WPPI's feedback and would add the following with regard to MISO's proposed RCP changes:
I am happy to discuss.
David Sapper
dsapper@ces-ltd.com
Environmental Sector Comments on
MISO’s Proposal to Remove Eligibility of DIRs to Provide RCP
The Environmental Sector appreciates the opportunity to provide this feedback on MISO’s proposal to remove the eligibility of Dispatchable Intermittent Resources (DIRs) to provide ramping via MISO’s Ramp Capability Product (RCP). Our sector understands the issue that today the RCP does not consider transmission congestion limiting the deliverability of a resource. Thus, DIRs are cleared to provide up-ramp capability when transmission congestion is resulting in the curtailment of those same DIRs. In this situation, because the DIR is producing below its forecast maximum, it looks like the DIR has the ability to provide up-ramp. However, the transmission congestion means that there is not sufficient transmission capacity to allow deliverability of that up-ramp. This results in a cascade of dispatch and pricing problems that causes efficiency losses. Our comments in the sections below aim to obtain additional clarity on MISO’s analysis, the proposed solution, future needs, and transparency and reporting.
MISO provided stakeholders with results from its analysis of DIR/Non-DIR participation in the RCP product. MISO presents two cases, characterized as “boring days” during the presentation. The cases show DIR having no value to provide ramp up, with Case 1 showing no stranded wind resulting in wind opting to offer energy, and with Case 2 showing stranded wind resulting in wind opting to offer up ramp when delivery isn’t actually possible because of transmission congestion. These cases are exacerbated by the fact that RCP is a system-wide product that can’t “see” congestion.
While these two “boring days” cases are helpful and may represent the majority of the intervals, we would like to know whether MISO considered other cases in order to study the instances when DIR may add value to the system? For instance, has MISO considered cases in which unplanned outages or other changes to non-DIR resource availability resulted in DIR becoming a needed source of up-ramp? Would MISO’s conclusions change if offers to provide RCP were able to respond to the existence of congestion? Additionally, stakeholders would benefit from understanding any other cases that have been analyzed by MISO in the course of its investigation.
Has MISO completed any evaluation of future resource mixes where the value of wind and solar providing ramping capability would be more cost effective? And, how will the role of increased Energy Storage Resources affect the procurement of up-ramp across the resource mix?
MISO presents changes in increased energy price for one of the intervals considered in the case. Stakeholders would benefit from understanding the market impact of the proposed change over a longer period, such as a year, ideally also showing potential seasonal patterns that may indicate how DIRs and non-DIRs participate in the ramp product.
While we understand the operational issues that underpin MISO’s proposed solution, which applies only to DIRs, we still believe that MISO should recognize that its proposed solution is facially discriminatory. Any resource that is operating below its capacity due to transmission congestion would have this same limitation due to deliverability constraints. Even if disabling DIR participation in its ramp product is needed as a temporary solution, MISO must commit to a long-term non-discriminatory solution that tackles the ramping product limitations to consider congestion, rather than remove a class of resources technically capable of providing ramp.
In its December 1st presentation MISO indicated that it plans to investigate the use of Reserve Procurement Enhancement (RPE) to account for zonal constraints when clearing ramp offers. MISO mentions this is already designed into RCP but not deployed and that it has experience with using this in its Short-Term Reserve product. The Environmental Sector recommends MISO pursue this as part of its proposed action to improve the Ramp Product instead of only disabling DIRs. Additionally, MISO should clarify to stakeholders why it is prioritizing a temporary solution rather than a more comprehensive solution such as RPE? What would be the timeline for pursuing this product improvement? Insight into what MISO is thinking regarding the medium term would be helpful to stakeholders.
Again, to the extent that MISO proceeds with this proposal, the Environmental Sector recommends MISO include text in its proposed tariff language changes indicating that this is a temporary disabling of DIR while MISO works on a medium to long-term solution. Our suggested redlines of the tariff language provided by MISO in the December 1 MSC presentation[1] are as follows:
Module A: Up and Down Ramp Capability Qualified Resource
“Up and Down Ramp Capability Qualified Resource: A Generation Resource, External Asynchronous Resource, Demand Response Resource-Type II, Stored Energy Resource – Type II, Electric Storage Resource, or Distributed Energy Aggregated Resource that has met the requirements to be eligible to provide Up and Down Ramp Capability by submitting Up and Down Ramp Capability dispatch status other than ‘Not Participating’ into the Energy and Operating Reserve Markets. Dispatchable Intermittent Resources are temporarily disabled from inclusion in this category.”
39.2.1B.D Resource Requirements for Up Ramp Capability and Down Ramp Capability
“Up Ramp Capability and Down Ramp Capability eligibility in the Day-Ahead Energy and Operating Reserve Market will be limited to (i) committed Generation Resources, but temporarily disabled for Dispatchable Intermittent Resources, (ii) available External Asynchronous Resources, ...”
40.2.4.d Resource Requirements for Up Ramp Capability and Down Ramp Capability
“Up Ramp Capability and Down Ramp Capability eligibility in the Real-Time Energy and Operating Reserve Market will be limited to (i) on-line and synchronized Generation Resources but temporarily disabled for Dispatchable Intermittent Resources, (ii) available External Asynchronous Resources, ...”
Schedule 28: VII: Market-Wide Down Ramp Capability Demand Curve
“The Market-Wide Down Ramp Capability Demand Curve price will be temporarily set to $0/MWh, to disable the product after the temporary removal of Dispatchable Intermittent Resource eligibility while MISO considers further improvements to its Ramp Product.”
For the purposes of the above tariff provisions, MISO’s legal department would also need to define instances of “temporary” or “temporarily disabled” in order for such terms to have an actual and substantive impact.
If MISO does move forward to file its proposal with FERC, the filing must include a commitment and a timeline for developing and implementing a different non-discriminatory solution. We suggest that MISO tie such temporary requirements to a new provision requiring MISO to regularly assess the real ability of DIRs to provide up-ramp, such as is recommended in the below section, and the real ability of new market products to account for up-ramp ability on a more discrete geographical basis.
MISO must not let the effort to develop another solution lag too long, because as the generation mix changes to higher levels of renewables, operations will need more up-ramp capability, as is indicated in MISO’s recent Regional Resource Assessment (RRA) Report. Slide 7 from the posted November 30, 2022, RRA presentation shows that as the solar generation fleet grows, the need for up-ramp capability will increase threefold by 2031, and fourfold by 2041. Thus, MISO will need DIRs to be able to participate in providing up-ramp in the future, even though it may not be as cost effective for DIRs to do so today.
We also recommend that MISO include additional slides in the markets and operations monthly report that will provide transparency on the needs for up-ramp, up-ramp availability, as well as deliverability issues with up-ramp, so that all stakeholders can have a better understanding of this issue as the resource mix evolves and transmission infrastructure changes.Specific monthly metrics for reporting may include:
Additionally, the Environmental Sector recommends MISO communicate to stakeholders what metrics will be used when monitoring the performance of the RCP product to determine when DIR should be enabled.
[1] MISO, MSC Item 06: Ramp Product Enhancements, December 1, 2022, available at https://cdn.misoenergy.org/20221201%20MSC%20Item%2006%20Ramp%20Product%20Enhancements627169.pdf.
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the December 1st, 2022, Market Subcommittee (MSC) meeting concerning MISO’s Proposed Ramp Product Enhancements.
The EOCs agree with the proposed policy change. It’s imperative to not inadvertently rely on resources that wouldn’t actually be able to clear energy should the need arise.
One area of concern for the EOCs are unintended consequences in setting the ramp down price to $0. MISO didn’t provide any concrete data around historical clearing prices for Ramp Down, only giving broad generalization around historical clearing prices. To set the price to $0 could undervalue this product in the future. We would appreciate if MISO could present historical Ramp Down clearing prices and agree to revisit the economics around Ramp Down in the future. Even if the Ramp Down is a low value product currently, we should be sure we’re not undervaluing it in the future by fixing the price at $0.
The EOCs appreciate the opportunity to comment
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
WPPI feedback on the questions posed by MISO re the proposed changes to the Ramp Capability Product discussed at the 12/1/2022 MSC:
Southwest Louisiana Electric Membership Corporation (SLEMCO) agrees with the direction MISO is taking and the recommended tariff modifications on the development of these Ramp Product Enhancements. SLEMCO concurs with the need to ensure that both offers for ramp-up and ramp-down capability are reliable and have a high probability of being available for use by MISO system operations when needed.
ITC supports MISO’s focus on deliverability for procured Ancillary Service products. We support evaluation of deliverability as part of MISO’s product procurement process. Where products are repeatedly not deliverable (metrics around this could be developed), we propose that the congestion impacting deliverability be documented and evaluated as part of the congestion planning processes (such as the Market Congestion Planning Study (MCPS) or other MISO market efficiency studies).
ITC supports MISO’s focus on deliverability for procured Ancillary Service products. We support evaluation of deliverability as part of MISO’s product procurement process. Where products are repeatedly not deliverable (metrics around this could be developed), we propose that the congestion impacting deliverability be documented and evaluated as part of the congestion planning processes (Market Congestion Planning Study(MCPS) or any other MISO market efficiency studies).