RASC: BPM-011 RAN Seasonal Implementation Draft Language (RASC-2019-2, 2020-2, 2020-3) (20220824)

AMP and MPPA support WPPI's feedback.

I'd be happy to discuss.

David Sapper

dsapper@ces-ltd.com

Consumers Energy appreciates the opportunity to provide feedback on the draft BPM-011 language for RAN Seasonal Implementation.

In general, there are several references to resources providing at least one season or the most recent consecutive three seasons of historical performance data. It would be helpful to clarify whether reference to a season and historical previous/consecutive seasons are for the same season over previous years or three consecutive seasons that are within a given planning year (example: winter 2021, winter 2020 and winter 2019 vs. fall 2020, winter 2021, spring 2021).

(P36) "NITS SRsshould" typo should reflect "NITS SR should"

(P 44) 4.2.3.3.1 Wind capacity is based on all historical data since operation. How will this be merged from annual to seasonal? Will this be limited to the most recent three years of data under SAC?

(P148) Wind Capacity Credit by CPNode Calculation - will these values be recalculated back to 2005 or reflect say top 8 peak hours for each year from 2005-2022 and each season from 2023 forward?

Would like to see more clarification on the BTMG and DR qualification requirements that state: 

4.2.8 BTMG:  "capable of being interrupted and available at least the first (5) times as needed during the Summer and Winter and at least the first (3) times as needed during the Spring and Fall by MISO or the LBA for emergency event purposes"... 

4.2.9 DR:  "capable of being interrupted and available at least the first (5) times as needed during the Summer and Winter and at least (3) times as needed during the Spring and Fall as needed by MISO or the LBA for Emergency purposes"... 

Is this a total of 16 times per year that these resources must be able to respond?  Or is it 8 times?  Either way, that's a big increase from prior requirements.  And, I'm not sure I understand why "first" is included in the language. 

Suggest the language be standardized and modified to "capable of being available and utilized a minimum of X times as needed during the summer season, a minimum of Y times as needed during the winter season, a minimum of Z times as needed during the Spring season and a minimum of ZZ times as needed during the Fall season by MISO or the LBA for emergency event purposes ..."

Consumers Energy appreciates the opportunity to submit additional feedback for BPM-011 and related seasonal/SAC accreditation questions as noted below.

BPM REDLINE COMMENTS:
In the BPM redlines on Page 244 1.2.2 (3) and Page 245 1.2.3 (Tier 2 RA hours (3), which are the calculation for accreditation sections (not RA hour identification) it calls out a cold start of 12 hours instead of 24 hours. We believe this should be 24 hours in both of these instances. 12 hours is only utilized to determine RA hours not to calculate accreditation.

Appendix H has the ERIS/NRIS requirements under it but now states this is only for non-schedule 53 resources. Please confirm this is correct.

SEASONAL CONSTRUCTION QUESTIONS:
1. Please confirm that ZRCs may be registered in multiple seasons but not necessarily all seasons. For example, a resource or program may be a certain number of ZRCs in the summer but zero ZRCs in the fall, winter, and spring seasons?
2. If an outage is shortened in CROW (less than 20% difference), would the exemption be lost if the maintenance margin reflects <0 on any day at the time and day when the previously requested outage period is updated to reflect the shortened outage duration?
3. For replacement ZRCs for a unit that will be in outage for >30 days, can a Market Participant utilize the ZRCs from the unit on the days it is not in outage and only purchase ZRCs once it goes into outage?
4. Are there new event windows for DR by season?
5. For Maintenance Margin, does one only need to consider the maintenance margin in a specific region (Central) or must one consider MISO’s overall maintenance margin as well as our specific region for the Tier 2 exemption?
6. When will Tier 2 hours be provided from the previous season? Would this be within 30 days of the season ending or once annually after a planning year has ended?
7. Are pumped storage and reservoir hydro facilities considered Schedule 53 resources?

The BPM does not define the difference between a Schedule 53 Resource and a Non Schedule 53 Resource.  The distinction should be defined in the BPM. 

Regarding XEFORd - how are outages counted for seasonal XEFORd calculations if the outage crosses seasons or crosses months? 

WPPI thanks MISO for allowing additional time to submit comments on the BPM edits.  We have reviewed edits to the main BPM text, but not yet the appendices.  We offer comments below, and are separately submitting a marked-up version of the document.  We do believe at least one additional round of review will be necessary to make the BPM an appropriate guide to the seasonal process.

1. We appreciate the posting of a .docx version of the BPM to facilitate stakeholder review and communication back to MISO.  It appears that, prior to posting, MISO takes a step to identify all MISO changes as associated with ‘Author.’  This is reasonable as there is no reason to identify individual MISO staff in the posted document.  It would be helpful to stakeholders, however, if MISO could change document settings back before posting so that stakeholder comments do not also revert to being associated with ‘Author’ (thereby becoming difficult to distinguish from MISO’s changes).”  The setting changes at issue are described here: https://erinwrightwriting.com/how-to-stop-microsoft-word-from-calling-you-author-in-track-changes/.  This would be very helpful to WPPI and, we expect, other stakeholders, who may begin to edit the document before realizing that it includes this setting.
2. We appreciate MISO’s efforts in many areas to make the BPM language more concise.
3. In some areas the BPM would benefit from more extensive re-writing rather than mere modification to the existing structure.  We suggest this in several specific places in the red-line document we are submitting with these comments.
4. As we indicated at the August RASC meeting, WPPI supports MidAmerican’s proposal to allow late-registered or late-qualified Resources to be eligible to be used for Replacement within a Planning Year.  The posted minutes for that meeting report that:

• The chair asked stakeholders to review the draft BPM-011 language regarding this issue and respond via the feedback request, and MISO committed to responding in October whether tariff changes are required.

We note that BPM includes new language in 6.3 that concludes that:

• MISO holds firm that an “uncleared” ZRC must necessarily be registered prior to the PRA in order for it to be eligible [to be Replacement capacity within the Planning Year].

This BPM language strongly suggests that a tariff change is needed to achieve the desired state.

5.  MISO discusses must-offer requirements (at length) in Section 4, and then again in Section 6.  We recommend eliminating the discussion of must-offer requirements in Section 4 (Qualifying and Quantifying Planning Resources) and reserving this discussion for Section 6 (Performance Requirements).

6.  The BPM refers to ‘Non-Intermittent Generation Resources’ which is not a term used in the tariff.  We recommend abandonment of this term in the BPM.  With FERC approval of Schedule 53, Schedule 53 Resources (defined in Schedule 53, including DRR) should be the first category considered in Section 4 (Qualifying and Quantifying Planning Resources), followed by the categories carved out by the Schedule 53 Resource definition:

• Dispatchable Intermittent Resource or Intermittent Generation
• Electric Storage Resource
• Stored Energy Resource – Type II
• Use Limited Resource
• QFs
• Hybrid Resources
• External Resource that does not fall into some other category, such as Intermittent Generation

Alternatively, consider using “Generation Resources that are not Dispatchable Intermittent Resources”

Please consider this informal feedback on SAC Implementation since the new submittal mechanism is not yet in place.

At the 8/24/22 RASC meeting, on slide 7 of the presentation for Agenda Item 7a RAN (SAC) Implementation, MISO said it would publish SAC values for Sept 2018 through Aug 2021 in November.

Given the tight timeframe and the difficulty estimating SAC that every resource owner I have polled is experiencing, MISO should instead focus its limited resources on publishing SAC values for Sept 2019 through Aug 2022.  Data that determines accreditation for the PY'23'24 PRA is essential, whereas data that would have determined SAC for previous PRAs is at best nice to know and at worse a waste of scarce resources when it can least be afforded. 

We appreciate the opportunity to comment. 

In the BPM on page 32,  Module E and Commercial Model data do not align. How will jointly owned resources be managed to determine Asset Owner charges and seasonal registrations?

We suggest that MISO clarify that seasonal element requirements throughout the BPM document.   

If resources become available mid-year, how can they be leveraged effectively?

Thanks,

Joan Soller  

MidAmerican Energy appreciates the opportunity to provide feedback on the BPM-011 language for RAN Seasonal Implementation. MidAmerican would like to recommend that the BPM-011 language be edited to include mid-planning year accreditation. As discussed in the August 24, 2022 RASC meeting, this issue has become even more important as we transition to RAN Seasonal Implementation given the requirement to use replacement ZRCs for outages longer than 31 days.

BPM-011 Sec 6.3 and Module A of Tariff - ZRC definition - “A MW unit of Planning Resource which has been converted from a MW of Unforced Seasonal Accredited Capacity to a credit in the MECT..."

BPM-011 Appendix A - "In MISO’s seasonal construct, each season establishes a baseline of 0.25 days/year so that the summation of the seasonal LOLE equals the industry standard of 0.1 days/year." - is this true for ELCC analysis of wind?  - is it true for MISO LOLE study?

Xcel Energy has sent a marked-up version of the BPM redlines to Stakeholder Relations.  All revisions are identified with a comment bubble for ease of use.  Thank you.

RAN Implementation

• The presentation of details for the SAC calculation in CCE appears deficient.  More detailed data and calculations need to be made available for download.  On the RASC, MISO indicated that it is working on methods to provide more data, and Duke appreciates that.
• We don’t see how to download all hourly data to view the ISAC calculation (hourly offers, outage data, limitation to ICAP, AAOC, etc.).  All you can see and download is the summary level data for the components of the calculation, but not the hourly data.  This level of data is insufficient for market participants to validate MISO’s determination of the ISAC values.
• We don’t see how to download the Tier 1 and Tier 2 hourly data (inputs and calculation of the hourly margin, showing of MaxGen events and calculation of remainder of Tier 2 hours)
• You can download Tier 2 hour datestamps, but not in 8760 format, and you can only download one season of one year at a time (very tedious to get everything out to build the entire 3 years of data), plus then you have to backfill all other hours yourself to get a file in 8760 format
• This level of data is insufficient for market participants to validate MISO’s determination of the Tier 2 hours
• CCE appears to be showing structure for ISAC and SAC calculations for resources not in Schedule 53 (hydro, wind, solar, and external resources).  If MISO intends to intermix resource types on one screen, then additional data columns are needed, including XEFORd for example, and the calculations for each type of unit should be clearly differentiated, identified, and made available for download.
• During the stakeholder meetings it was made clear that MISO was increasing what was originally the 30-day rule to 31 days, to account for the maximum length of any month.  The BPM Redline reviewed by Duke still referenced "30 days" and not the 31 days MISO discussed.  Please make all changes where appropriate in BPM language.

 BPM-11 Redlines (specific to LMRs):

1. Duke request consistency regarding LMR capability.  At various times the terms “MISO’s Coincident Peak”, “MISO’s Seasonal Coincident Peak”, and “Seasonal peak” are all used.  Examples can be found in sections 4.2.9, 4.2.9.8, Appendix D.
2. Duke requests clarity regarding Testing Requirements for LMRs.  Under section 4.2.9.8, the BPM states that Demand Resources “shall demonstrate seasonal demand reduction capability…”.  However, the BPM is not clear if a test is needed only annually or if a test must be carried out for each season.  While Duke suspects DRs will only need to test annually, clarity would be appreciated.
3. Duke requests clarity regarding a new statement placed in the first paragraph of section 6.4.2.  The statement notes “DRs that registered with a firm service level Measurement and Verification methodology must still show a [load] reduction to their firm service level in response to scheduling instructions or be subjected to the penalties described above.”  Duke notes that LMRs which are self-scheduled or otherwise already below their contracted firm service level will not show any additional reduction.  Clarification would be appreciated that in such a scenario MISO would not penalize such an LMR.

Alliant Energy is concerned that MISO’s BPM language for new solar accreditation (without performance history) is not clear. One section indicates solar receives 50% accreditation – is that for all seasons? (see page 232 of 251). Another section indicates “class average” (see example on page 233 of 251). For the sake of consistency and to provide certainty, MISO should revise BPM-011 to clarify the percentage accreditation rate for each season.  If a class average reference is used, MISO should explain where and how that class average is determined (e.g., annual wind and solar accreditation report?).  See page 168 of 251 for MISO’s language around new wind – something similar should be written for solar.

 Alliant Energy is also interested in immediate action on BPM and Tariff changes to accommodate on-ramping of new resources, as a replacement capacity opportunity, consistent with MidAmerican Energy’s presentation to the RASC. This should be a top priority and not ruled “out of scope” to existing efforts. The stakeholder body expressed a loud need for this immediate change.

The draft BPM update is a 250-page post-only item with edits throughout the document.  We are unable to complete a thorough review by the feedback deadline.  WPPI requests that MISO significantly extend the review & comment period beyond the two weeks of the current feedback request for these potentially very important changes.