RASC: LMR Accreditation Feedback (RASC-2019-2 2020-4) (20220713)

ITC Holdings Corp. (“ITC”) appreciates the opportunity to provide feedback on LMR Non-Thermal Accreditation.

ITC supports any and all efforts by MISO and stakeholders to better align LMR accreditation with their actual availability during times of need.  We also support improved situational awareness and real-time reliability through better transparency on LMR locations and quantities.

While LMR resources can provide significant value to the BES, more realistic accreditation and better locational transparency will help support BES reliability both today and into the future.

Alcoa Power Generating, Inc. (APGI)

Comments On

RASC: LMR Accreditation Feedback (RASC-2019-2 2020-4)

August 03, 2022

During the July 13, 2022, Resource Adequacy Subcommittee (MSC) meeting, MISO requested feedback on Load Modifying Resource (LMR) Accreditation.

As a MISO Market Participant and Load Serving Entity with LMRs in the MISO system, Alcoa Power Generating Inc (APGI) has specific interests in the accreditation process for LMRs. APGI recognizes that MISO is in the early stages of examining accreditation process and looks forward to upcoming discussions.

MISO asked for feedback on the following specific questions on “How should MISO address the Load Modifying Resource (LMR) accreditation gaps described today?”  APGI is responding to only one of the questions, because this is the most relevant to APGI operations.

• Current LMR accreditation misalignment with MCS availability during times of need

To truly understand this issue, APGI believes that MISO needs to break down the information better. It is the understanding of APGI that this apparent misalignment may not be as significant as initially appears from reviewing the information because MISO does not break out “self-committed” resources and resources that are registered to curtail to a firm service level. For example, APGI has multiple behind the meter generators that are typically self-committed to their full output, whenever available. This means that hundreds of MW of generation are often shown in the MCS as offering 0.0 MW for MISO to dispatch, because they are fully self-committed by APGI to meet APGI load. This example would show a very skewed availability gap when there is no gap at all. If there are other similar examples of industrial BTMG, then the availability gap would not be as large as it may appear.

Similarly, demand response resources that reduce to firm service level or are available when the load exists (i.e., air conditioner loads), should be broken out to understand the data. If a 20 MW peak load can curtail to 5 MW, but is only running 10 MW, then the available curtailment is only 5 MW, but the resource is fully meeting its obligations.

To make informed decisions on next steps and potential solutions, it is important that MISO break down the information on LMRs in the MCS to understand the root causes of what appears to be unavailability relative to capacity cleared in the PRA.

APGI would also ask MISO to consider removing duplicative reporting requirements by linking the CROW data entry to the MCS or facilitating the removal of the MCS availability requirements in situations where CROW data is required.

APGI appreciates the opportunity to provide feedback on this issue.

If there are any questions or comments, please feel free to reach out to:

Steve Dowell

ESS LLC, Alcoa Power Generating Inc.

(812) 853-1135

Steve.Dowell1@alcoa.com  

DeWayne Todd

DDT LLC

(812) 573-8052

dewayne.todd1@alcoa.com

Sherry Rhodes

Alcoa Power Generating Inc.

(812) 853-1033

Sherry.Rhodes@alcoa.com

At this time, WEC Energy Group does not support any changes to the accreditation of LMRs.  We believe the apparent reduction in LMR availability when compared to what clears in the PRA is the direct result of the load associated with demand response already not consuming.  For example, 20 MW of demand response that is consuming 10 MW in real time will only have 10 MW available to curtail.  Recent enhancements to the Demand Response Tool within the MCS will allow more granular reporting of DR availability based on the amount of DR that is already not consuming.  Direct load control is another example of how LMRs will differ in availability and what clears in the PRA.  Air conditioning load subject to direct load control is probably not consuming during the winter months.  A 100 MW direct load control program that consists of air conditioners will appropriately show 0 MW of availability in the winter because that load is not on the system to begin with.

As noted in the presentation at the July 13 RASC, beginning with Planning Year 2023-2024, LMRs are required to have notification times of 6 hours or less to receive accreditation.  This notification time is already well within the 24-hour notification cutoff within proposed Schedule 53 and we do not believe further reduction of the LMR notification time is needed or justified.  While the proposed Schedule 53 24-hour threshold for accreditation with respect to offline resources reflects MISO's ability to commit a resource in its Day-Ahead Market or Forward Reliability Assessment Commitment processes, MISO must still project tight system conditions to commit a long-lead time resource in the DA or FRAC.  Similarly, MISO has the ability to notify LMRs well in advance of the 6-hour notification that the LMRs may be needed in real time.  In short, MISO (and most MPs) know much more than 6-hours in advance of tight system conditions and the potential need to implement emergency MaxGen procedures.

Regarding locational information, LBA-level locational granularity is sufficient in most operational situations.  In those situations where an LBA spans a well-established export constrained boundary (such as NDEX, MWEX), we support the development of sub-LBA "LMR areas" to ensure proper deployment of LMRs (but only for those LBAs that span export constrained boundaries).  Ultimately, the LBA is responsible for the deployment of LMRs within its footprint and may not have the contractual ability to call on some LMRs, but not others.

Duke Energy's feedback: 

1. Duke would request MISO consider inclusion of a “Maintenance” field or similar within the DSRI specifically to assist MISO with having visibility into LMRs which are unavailable.  For example, many Demand Resource LMRs are large industrial customers who have agreed to curtail load to a Firm Service Level when called upon.  These same customers often reduce facility load significantly for maintenance or other reasons.  This activity differs from periods where these same customers may curtail for economic reasons, which results in “Self-Scheduled” MWs in the DSRI.  A means by which to communicate to MISO when MWs are unavailable due to ongoing maintenance or similar may be helpful in providing clarity to discrepancies between MWs available in DSRI and MWs originally bid into the PRA.  Note BPM-11 notes “if the LMR is on any type of outage or otherwise not available, the LMR availability should be adjusted by decrementing LMR availability in the DSRI by reducing the ‘MWs available for MISO’ for the affected LMR”.  However, given this decrement is not documented by the MPs, MISO may not have any way to know whether an LMR is on maintenance irregularly or habitually.  Having this insight may better determine how to address this misalignment between PRA and DSRI.
1. Particularly when called upon for dispatch, Duke believes there may be differences between what capability value is desired by MISO in the DSRI beyond the “maintenance” issue mentioned above.  BPM-11 directs MPs to “communicate to MISO their availability through the [DSRI].”  The MECT, which provides the default values for the DSRI at the point the LMRs are originally registered similarly asks for “…the amount of MW you can curtail in a given month…”.  It appears evident MISO desires an indication of expected load drop in real terms (ie: how many actual MWs of relief can be expected by hour and day).  While literal hourly capability is likely the most useful metric to MISO when requesting curtailment, these values are not consistent with how MPs will be held financially accountable during the Settlement process.  Duke believes MPs may be managing availability within the DSRI in a manner consistent with how they will be settled with financially.  This consequence likely results in general managing of LMR (DR) MWs that are oftentimes less than those registered during the PRA, particularly if/once called upon during an event.  Actual load drop in these cases is likely much higher than the MP will be given credit for, but due to the default M&V methodology – which will be applied for Settlement purposes – availability within the DSRI is likely reduced to reflect a value lower than that bid into the PRA.  For example, if a large industrial facility registered as an LMR with a FSL has experienced reduced load levels over some of preceding days within the 10 of 10 baseline period, the availability as listed in the DSRI may be much reduced below the actual curtailment expected from that customer.  Even with the application of SMA, adjustments are limited to 20%.  As the MP will be held financially responsible for the result value having applied the M&V methodology, this lower amount will be submitted in the DSRI.  MISO should take care to note this differs from an LMRs inability to fully perform (ie: to reach the FSL), which is a separate issue.
2. Duke would generally agree with MISO that circumstances leading to LMR deployment tend to leave minimal time to react.  MISO should continue to consider what notification times are appropriate.  While likely self-evident, Duke would note there is a risk of losing a measure of LMR capability (particularly DR) should maximum lead times be reduced further.  However, the highest risk would lie with further reducing the minimum required notification time of two (2) hours.
3. Duke agrees with MISO that prudent locational information would be helpful for managing LMR deployment from MISO’s perspective.  Duke would note, however, that for smaller LMR resources – particularly residential and SMB loads – requiring locational information for each component resource would be burdensome given the current structure of the MECT.  In practice, such individual loads are typically aggregated into a single resource, which generally reflects their operation (all component resources will be dispatched together if the resource is called upon).  This said, having a means by which to submit locational data in a manner that would continue to allow for aggregation of such resources would be preferred.  Another approach to consider may be a minimum capability size (component resource basis) over which locational information must be provided.  Even in these cases, Duke would have sensitivity to any approach that would result in individual component resources needing to be registered in the MECT on an individual basis (versus an ability to aggregate).
4. No comment for Intermittent BTMG.

See PDF file e-mailed to Stakeholder Relations.

MISO has requested stakeholder feedback to the topic of LMR Accreditation as presented in the July 13, 2022 Resource Adequacy Subcommittee (RASC) meeting.

Voltus provides the following feedback in response to this request:

How should MISO address the Load Modifying Resource (LMR) accreditation gaps described today?  

Current LMR accreditation misalignment with MCS availability during times of need 

Voltus supports MISO’s efforts to review LMR accreditation, with a goal of better aligning accreditation and availability during times of need. Given that capacity accreditation reviews are underway in several RTOs, MISO’s review is timely. Still, significant additional analysis is needed before MISO revises its capacity accreditation for LMR, a concern many expressed at the July 13 meeting. MISO’s analysis presented in the July 13 meeting was incomplete in several ways:

1. Historical MCS data is not a full and accurate reflection of LMR availability. Dual enrolled LMR/EDR resources manage their availability through EDR offers, rather than as LMR in the MCS (now DSRI) portal. Prior to 2021/2022, LMR was only a Summer product, so LMR resources only had to be available for the Summer to achieve full accreditation and would typically show as unavailable outside of Summer months in the MCS.  MISO admitted that its analysis also failed to account for self-scheduled BTMG/DR running during peak hours, or MPs that have self-scheduled their own LMRs for their own reasons (e.g. high pricing, tight local conditions). Without accurately controlling for these factors, MCS data cannot and should not be used to change capacity accreditation for LMRs. 

2. LMR was designed to meet system needs during peak conditions, which are not always one and the same as tight conditions. LMR registration capacity is based on the asset’s load as “calculated as the average load of the assets up to the last three Annual (or Seasonal when applicable ) MISO system peak hours[.]”

1. An LMR’s load during the MISO system peak might not correlate with the system’s “tightest 65 hours” that MISO studied. For example, forced outages and a wind lull could result in “tight conditions” even when demand is short of system peak. This is essentially the scenario that prompted the June 2021 LMR dispatch.

2. MISO should consider how the tightest hours in its analysis correlate with peak load conditions, as opposed to other potential scenarios that can result in reduced operating margins - including reduced solar production; reduced wind production; forced outages due to extreme heat; shoulder season outages - that may not be as informative for understanding availability in system peak load conditions.

Stated differently, unless and until MISO gives notice to MPs that accreditation of LMR registrations will be based on the expected availability during the system’s “tightest 65 hours” of the year, MISO should not assign a capacity accreditation based on this metric nor expect availability to match accredited levels outside of peak conditions.

3. MISO should conduct analysis using different sample sizes of tight system conditions, rather than just the 65 tightest hours. Demand response resources are uniquely well positioned to respond to grid emergencies in peak load conditions because their availability inherently increases as overall grid load increases.Depending on how actively MPs adjust availability values, MISO should theoretically see higher availability in the very tightest hours than in the more broad 65-tightest hours currently used. Demand response availability naturally aligns with need.

1. It would be informative to analyze how availability changes in a series of “stepped” scenarios according to the sample used: the tightest 65 hours, the tightest 50 hours, the tightest 25 hours, the tightest 10 hours, etc.

4. Historical availability data was set under a very different set of rules and financial incentives, so should not be used to reduce capacity accreditation for LMRs into the future. MISO should ensure the roll-out of any new accreditation methodology is commercially reasonable, and does not rely on historical data provided under alternative Tariff language, as using historical data in this way would constitute retroactive rulemaking.

Need for fast responding LMRs 

MISO’s revision 25 of BPM 11 has already made some progress in aligning MISO’s need for faster-responding LMRs with capacity accreditation. Previously, resources with 12-hour notification times were accredited equally with 2-hour notification times. From Planning Year 2023/2024 onwards, this threshold has been decreased to 6-hours.

Decreasing this accreditation threshold further still could result in participation becoming prohibitive for some LMR resources. Still, we recognize that the accreditation of resources should scale with the value that these resources provide to the market under emergency conditions: as such, MISO should consider higher accreditation being awarded to resources registered with the minimum 2-hour notification.

In addition, some focus should be on forecasting emergencies so that Scheduling Instructions can be sent out with 6-hours advance notice to ensure the market is able to take advantage of the capacity that resources with longer response times can provide.

Lack of accurate LMR location information 

Voltus is the most active ARC in MISO, and we already provide detailed location information when enrolling LMRs. The LMR registration process in the MECT tool requires registering parties to include a physical address associated with each account number being submitted, and as an ARC, Voltus is held to very high standards in the registration process pertaining to this data. Even minor discrepancies in address data (for example, using a street address “1018 North St” would be rejected by the LBA if the address on the LBA bills were “1028 North St”). 

Utilities should be held to the same standard as ARCs so that all MPs registering LMRs provide locational data that meets (but does not exceed) MISO’s needs for specificity.

Intermittent BTMG availability not pushed to MCS 

Voltus does not have any comments regarding this portion of the feedback request.

LMR accreditation: The disparity between cleared ZRC's in the PRA and actual availability during times of need is concerning. Can MISO clarify that the reduced availability during RA hours is not because the LMR's have chosen to self-schedule their MW, thereby rending their availability lower?

LMR accreditation should be treated fairly and consistently with the RA accreditation framework of other capacity resources.

Notification times for LMRs may not need be reduced, but perhaps the threshold for reaching EEA2 Step 2a is not sufficient if it doesn't give operators ample time to deploy available emergency assets.

Locational information by zip code is not a good idea - LMR aggregations may span many zip codes or many counties.  I agree that listing a zipcode of a parent company in a distant US state is misleading and not helpful, but requiring a physical zipcode of the asset is problematic too.

Locational information of an LMR at the CP Node should be sufficient, which is the current practice. Max Gen emergencies are often declared by MISO Region (North/Central/South) or footprint wide. I'm struggling to see the need for more detailed locational aggregation. MISO should demonstrate why listing location by CP Node (as is done today) is insufficient to manage local constraints.

Intermittent BTMG may not typically be throttled like a larger market DIR - they inject energy onto the distribution grid when fuel is available (sun/wind/river.). It's in their business model to produce as much electricity as often as possible when it's sunny/windy, so they aren't typically curtailed off-line waiting to be dispatched. Also I'm not sure it's practical to provide real-time generator output to MISO operators from individual BTMG's, especially if they are aggregations of many smaller assets. If MISO wanted to estimate the likely RT generation from BTMG's it could be modelled by MISO from wind speed and solar irradiation geospatial data paired with approximate BTMG location. But again, the generators are often maxing out their capabilities 24/7, they aren't holding back available MW waiting for a dispatch instruction.

I don't think MISO operators need access to dispatch Intermittent BTMGs or be aware of available MWs, since the BTMG owners are likely operating at full capability. The extra LBA operator effort to maintain this data in DSRI would be extraneous overhead and wouldn't provide value to MISO.

AMES, AMP, and CFU generally support MPPA's feedback.

Thanks for the opportunity to provide feedback.

David Sapper

dsapper@ces-ltd.com

WPPI Energy supports the comments of MPPA on this item.  We have the following additional comments:

Regarding Current LMR accreditation misalignment with MCS availability during times of need, WPPI sees several problems with the data presented on slide 32:

• Intermittent BTMG are already accredited on the basis of actual historic availability during identified critical hours.  MISO presents no clear reason to believe that this accreditation is not appropriate.  Accordingly, LMR MW quantities from these resources should not be included in cleared PRA results numbers that are compared to MCS-reported BTMG availability.
• As presented, it is not clear how much of the deficiency is attributable to limited BTMG availability and how much to failure to report availability.  We would request that MISO endeavor to provide this information in any future discussion of this topic.
• We don’t believe it is proper or meaningful to compare cleared PMR quantities with MCS-reported quantities unless Firm-Service Level DR LMRs are properly accounted for.
• Within a season, RA Hours should generally be focused on peak conditions, but may reflect a range of weather conditions.  Accordingly, there may be appreciable variation in DR availability (as reported, e.g. on slide 32 of the July 13 RASC presentation) across RA hours, and we would request that MISO provide standard deviations along with averages in future reporting of DR availability.
• MISO compares PRA results under the current summer-focused annual construct to LMR availability reporting in multiple seasons.  We recognize that current LMR accreditation may not be appropriate for non-summer seasons, and may need to be changed to be compatible with a seasonal capacity construct.

Regarding Need for fast responding LMRs, we have the following comments:  

• MISO recently tightened notification-time requirements, requiring revision of DR contracts in many cases.  MISO also changed its operational practices to allow advance instructions for longer-lead-time LMRs.  Before considering further changes, we would like to have MISO report on its experience providing advance instructions to longer-lead-time resources.
• Generally, we would prefer to see MISO working to figure out how to make use of LMRs on its system rather than disqualifying additional classes of resources.  As suggested at the July RASC meeting, this might include steps such as:
  • Tracking actual deployment hours in addition to distinct deployments, so that a given cancelled deployment or short deployment might not count as an entire 4-hour deployment

Regarding Lack of accurate LMR location information, WPPI would be willing and able to provide this information for our own LMRs.

Finally, regarding Intermittent BTMG availability not pushed to MCS, as discussed above, we expect that zero-marginal-cost intermittent BTMG LMRs will already be operating to the extent available, and in a manner consistent with their accreditation (which is based on actual historic peak-hour availability).  As such, it is not clear that more information on status of these resources is needed by or useful for MISO operators.  However, to the extent that this resource class includes non-zero-marginal-cost generators, which cannot be generally assumed to be operating at their capability, we would be open to discussing better observability for MISO operators, possibly similar to the former LMR-reporting situation we recall from several years ago.

DTE Electric appreciates the opportunity to provide feedback on addressing LMR accreditation gaps.

Accreditation misalignment with availability during times of need:

DTE requests that MISO clarify what is included in the “PRA Results” on Slide 32 – is this ICAP or UCAP?

DTE’s demand resources demonstrate their performance during at least one peak hour of the year, which is what BPM-011 Section 4.2.9.8 specifies as the testing requirement. For a proper comparison, MISO should look at the seasonal peak, not the average availability for the season. It would also be helpful to compare the seasonal peak to the seasonal registration rather than the PRA amount since some resources (such as Interruptible Air Conditioning) are not available year-round.

Need for fast responding LMRs:

Traditional generation can have lead times up to 24 hours, whereas LMRs must be available within 6 hours to receive full accreditation. This already offers a large advantage for deploying LMRs during emergency events. While DTE understands that it’s reasonable to require shorter lead times since LMRs are not offered in the day-ahead, we encourage MISO to be cautious about shortening the notification times too much.

If notification times are too short, large DR customers may not be able to respond in time without damaging their equipment (i.e., factories). Shortening notification times may risk losing significant customers, which would prove to be more detrimental during MISO emergency events. DTE would prefer to incentive fast response versus penalizing longer response times.

In addition, many of DTE’s notification times are specified within the interruptible tariff or in the terms and conditions (T’s & C’s) of programs. In order to change the notification time in the tariff language, DTE will have make regulatory filings which would delay the appropriate change and ultimately come down to a Commission ruling if the change is acceptable or not. For the programs where notification times are included in the T’s & C’s, customers would have to accept the updates which could lead to customers opting out or lead to natural attrition due to customers not wanting to go through the acceptance process again.

Lack of accurate locational information:

BTMG: DTE would support providing a more specific location for registered BTMG assets.

DR: DTE suggests defining a minimum demand response resource capacity that would require specific locational requirements. It would be much more reasonable to provide locations for larger customers, such as C&I, as opposed to residential demand response programs that may have thousands of customers enrolled. If specific locations are required for all DR programs, how would this impact their registration?

DTE would also suggest defining how specific the location needs to be. For example, DTE Electric’s service territory is pretty consolidated to the Southeast Michigan area. Would a region be specific enough?

Intermittent BTMG availability not pushed to MCS:

DTE supports adding intermittent BTMG to the MCS for visibility only. DTE’s intermittent BMTG is generally self-scheduled at its full capacity and visibility would not offer additional value for emergency situations.

Michigan Public Power Agency (MPPA), as a Municipal Joint Action Agency (JAA), has a portfolio of thermal generating units that are registered with MISO as Behind the Meter Generation (BTMG) Load Modifying Resources (LMR). Other Municipal Utilities and JAAs also have thermal BTMG LMR portfolios, as they have been part of the local public power business model since the inception of the power business in the USA.

As non-profit utilities with the obligation to serve our customers reliably and economically, MPPA and its Members take our role in MISO’s reliability very seriously. Attached is a rough thermal BTMG LMR availability analysis based on Demand Side Resource Interface (DSRI) data. We look forward to continuing to engage in constructive dialogue around the attributes of thermal BTMG LMR and how to best leverage them to support reliability and accredit the resources appropriately as reliable, dispatchable generation.

MPPA has specific feedback on MISO’s LMR accreditation presentation and questions:

• Do not use a historical Resource Adequacy (RA) hour approach, or hybrid approach including RA hours, for LMR unless an RA hour approach is approved by FERC in its Order on MISO’s Seasonal Accredited Capacity (SAC) filing in Docket No. ER22-495.
• Many thermal BTMG suspended/retired when MISO lowered the PRA qualifying Notification Time from 12 hours to 6 hours, decreasing rather than increasing resource availability. MISO should NOT further decrease resource availability by further lowering the PRA qualifying Notification Time.
• Require specific LMR Locational Information in Module E Capacity Tool (MECT) registration.
• MISO and stakeholders should develop a new mechanism for uneconomic thermal BTMG to participate in MISO without the costly requirements of the Demand Response Resource (DRR) mechanism. The new mechanism should enable, for example, a small BTMG with variable cost of $300/MWh to offer and be deployed with 2 hour notice for a 2 hour run without an emergency declaration, an ICCP connection or the need to follow 5 minute dispatch instructions.
• Analyze the need to modify LMR requirements for additional attributes that contribute to reliability, such as:
• Number of deployments (or cumulative deployment hours)
• Run time during Emergency Event.

Xcel Energy appreciates the opportunity to provide feedback regarding the Load Modifying Resource (LMR) accreditation gaps MISO presented in the July 2022 RASC. 

Current LMR accreditation misalignment with MCS availability during times of need 

Xcel Energy is not completely convinced that a significant gap exists between LMR availability during times of need and capacity accreditation.  Before we overhaul the LMR capacity accreditation methodology, we would like to see the gap evaluation incorporate the LMR capacity that may have been self-scheduled, from intermittent BTMG and from other acceptable reasons for the reduction.

Need for fast responding LMRs 

MISO has reduced the maximum notification time for LMRs to six hours and requires a minimum availability of 16 curtailments across the four seasons.  Since the LMRs with the shortest notification times are requested to be used after longer lead LMRs have been exhausted, perhaps MISO could incentivize new short lead LMRs by reducing the minimum curtailment event requirements for these resources.  We also agree that MISO should transition to an hours-based availability requirement instead of event based (i.e. LMRs should be available at least 20 hours in the summer instead of five events).

Lack of accurate LMR location information 

Xcel Energy supports the incorporation of location information for LMRs to identify the load resources that will be impactful during an emergency event when there is a binding constraint that splits an LBA.  Our preferred solution would be to provide the EP node (distribution/transmission substation) that each LMR is connected to.  This would still allow MISO to determine the amount of load relief within a particular area based on substations which MISO has included in their models.  We can currently control our interruptible programs using a dynamically selected boundary of physical addresses but do not have this capability with our direct load control programs.  Since the substation would be a fairly static location for each LMR and identified at one point in time, the control sub-groups would be readily available within the normal notification times. 

 MISO needs to allow time for LSEs to identify and incorporate the substation assignment into the registration and MCS processes.  In addition, upgrades to both the MECT and the MCS will need to be developed before this information can be submitted and processed efficiently.

Intermittent BTMG availability not pushed to MCS 

 Xcel Energy supports increasing MISO operators visibility into the amount of intermittent BTMG available on the system by pushing that data to the MCS. 

MISO RASC Feedback

Hoosier Energy Rural Electric Cooperative

August 3, 2022

Hoosier Energy Rural Electric Cooperative (“Hoosier”) thanks MISO for the opportunity to provide feedback on questions surrounding Load Modifying Resources (“LMR”) at the July 13^th, 2022, RASC meeting.

MISO requested feedback on current LMR accreditation misalignment during times of need, need for fast responding LMRs, lack of accurate LMR location information, and intermittent Behind the Meter Generation (“BTMG”) availability not pushed to the MISO Communication System (“MCS”). While Hoosier does not have a position on all these items listed by MISO, Hoosier does believe that more accurate information regarding LMR registration, location, and available load reduction should be pursued by MISO.

Hoosier has LMRs in our footprint and works with its distribution members to ensure that accurate information on those LMRs is submitted to MISO during the registration process for those that wish have Hoosier manage the LMR. Hoosier also has experience with third-party providers that contract with member loads to participate as an LMR in the MISO market and feels this process could be improved. Hoosier believes that there should be better coordination between LSEs and Aggregators of Retail Customers (“ARC”) prior to registration of LMRs and a more formal confirmation process between the LSE, ARCs, and MISO. On more than one occasion, Hoosier has had inaccurate load and location information be submitted for approval on LMRs on their system to MISO with limited time to verify the information which has diverted internal resources away from other crucial MISO-related responsibilities to track down this information prior to the registration deadline. Ensuring this information is accurate is paramount to Hoosier so that MISO operators know how much LMR capacity they have at their disposal within the Hoosier LBA when system conditions warrant needing them.

Hoosier believes a more formal process whereby the LSEs and the ARCs have adequate time to verify the information on the LMR looking to be registered and coordination with MISO on the registration is warranted. This would reduce errors and the last-minute push to ensure the LMR’s registration is accurate prior to the deadline.

Thank you in advance for considering this feedback.

The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback on MISO’s LMR Accreditation questions.

The EOCs have the following feedback and requests for MISO to consider:

• Notification Times: Given that MISO has recently made changes to the notification time requirements for LMRs, and those changes are not fully implemented, the EOCs believe that MISO should wait until those changes have gone into effect and their effectiveness has been evaluated based on that experience before deciding whether further changes to the notification requirements are needed.  In some cases, LSEs have pursued retail regulatory proceedings to revise their retail tariffs to ensure compliance with the revised notification times; further modifying those notification times would potentially require these retail regulatory proceedings to be repeated, and the resulting cost and time for the parties involved.
• LMR Location: The EOCs request that MISO please describe the process for how MISO currently decides which LMRs to curtail and how this curtailment process would be changed if individual LMR locations were known.
• Intermittent BTMG: Not all existing intermittent BTMG is metered. When deciding whether to introduce requirements related to intermittent BTMG it is important for MISO to consider whether it is feasible/reasonable for existing non-metered intermittent BTMG to be subjected to  the new requirements.

Consumers Energy appreciates the opportunity to provide feedback on MISO's Load Modifying Resource (LMR) accreditation questions raised in the July 13, 2022 Resource Adequacy Subcommittee meeting.

CE supports tiered incentives for LMRs that are capable of faster response to meet MSC availability during times of need.

CE supports software and/or registration improvements to provide more accurate LMR location information.

CE would be interested to hear what proposals MISO may have to address desired data frequency or granularity for intermittent BTMG availability.