RASC: Draft ESR Performance Factor Template (20220713)

The proposed BPM-011 language for ESRs states in Section 4.X.XX.2 that the ICAP value of an ESR is the minimum of ESR’s Power Rating (MW), Hourly Equivalent Discharge Amount (MW), and Transmission Deliverability (MW).  This is inconsistent with the ICAP value of other types of resources whose ICAP is not limited by Transmission Deliverability.  Transmission Deliverability is accounted for within the conversion of UCAP into ZRCs.  For example, Section 4.2.1.2 of BPM-011 states that, "In order for a Generation Resource to convert its entire calculated Total UCAP into Zonal Resource Credits, the Generation Resource must be fully deliverable up to its ICAP.  If a Generation Resource is not fully deliverable up to its ICAP, the resource will be eligible to convert a value less than the Total UCAP into Zonal Resource Credits as outlined in Appendix H."  Similarly, the deliverability for intermittent resources is accounted for in the conversion of UCAP into ZRCs.  See Section 4.2.3.2 of the BPM - "The portion of Total UCAP eligible to be converted into Zonal Resource Credits for an Intermittent Generation Resource or Dispatchable Intermittent Resource shall be determined utilizing the Deliverability Adjusted Capacity Factor method as outlined in the applicable appendices." ESRs should be treated comparably with deliverability applied when UCAP is converted to ZRCs rather than limiting the ESR ICAP.

At a previous RASC meeting and in response to prior feedback, MISO stated that the reference to SAC within the proposed ESR BPM language would be replaced with UCAP, until such time as the SAC proposal is approved by FERC.  However, the proposed language still refers to SAC.

WPPI provided comments on the draft BPM language for ESR accreditation a few weeks ago. We noted there that the formula for Hourly Equivalent Discharge Amount in that document did not clearly account for the need to ensure that “the Resource is able to continuously discharge for a minimum of 4 hours” that was articulated in a previous paragraph.  Similarly, the template does not make this requirement clear. If MISO intends this requirement to apply, it needs to make this clear in the BPM or template or (ideally) both.

In addition, we note that the template proposes to calculate the seasonal Unavailability Factors with respect to the (annual) Hourly Equivalent Discharge Amount in cell G8 of the ESR sheet.  It appears to us that, instead, each seasonal Unavailability Factor should be calculated with respect to the corresponding Seasonal Demonstrated Capability, which we assume corresponds to the seasonal adjusted values in cells I8-I11 of the ESR sheet.