RASC: Non-Thermal Accreditation (RASC-2019-2, 2020-4) (20220824)

Environmental Sector Comments on

MISO “Accreditation Reforms for Non-Thermal Resources” proposal

September 7, 2022

The Environmental Sector agrees with and supports the comments submitted on this same date by Clean Grid Alliance (“CGA”) in relation to MISO’s August 24, 2022 presentation on non-thermal resource capacity accreditation.  In addition to CGA’s thorough and cogent points, the Environmental Sector continues to urge MISO to take a holistic view of further reforms that are needed to meet system needs beyond the near-term need to bring wind and solar capacity accreditation in line with the thermal resource seasonal accreditation regime that was approved last week in FERC Docket No. ER22-495 (a decision issued after MISO’s most recent presentation).

MISO’s efforts at resource adequacy construct reforms thus far have not considered the role of energy storage resources or responsive load (other than which qualifies as LMR) in meeting system needs at times of the tightest margins.  While appropriate capacity accreditation for performance ability at peak-net load or other high-risk times is necessary for those types of resources, that may not be the only reform required to incent optimal performance.  Storage resources will be dispatched based on real-time price signals, and demand response resources (to the extent they have discretion over their curtailment) will also respond to real-time prices to make decisions.  The Environmental Sector notes that MISO announced[1] on September 1st the incorporation of energy storage resources into energy and operating reserve markets and emphasizes that appropriate price formation will be crucial.

The charging and discharging of energy storage resources will ultimately alter the loss-of-load risk profiles on the grid, just as time-varying renewable generation profiles do.  As higher capacity levels of storage are added to the system in the next several years, this change to the risk profile will be more pronounced. However, because storage dispatch (unlike that of renewables) is predicated on price signals, it is important that MISO attempt to incorporate reliability value into real time LMPs via the operating reserve demand curve or other scarcity pricing enhancements, in tandem with capacity accreditation.  This would help provide an incentive for storage, hybrid, and all other resources to respond during critical times of need, helping to ensure reliability. (The Environmental Sector notes the most recent presentation[2] shown to the Market Subcommittee about MISO’s scarcity pricing proposals in July 2022 and MISO’s intent to file those reforms at FERC soon, but notes that these proposals appear to not consider the reliability contribution of storage.)

As storage continues to grow in the MISO footprint in coming years with storage’s new inclusion[3] in the federal Investment Tax Credit and (after 2024) Clean Energy Investment Credit, MISO should plan for incorporating an accelerating presence of storage to help meet potential capacity shortfalls.  The planning construct’s ability to anticipate and mitigate operational risk will partially depend on whether it can incent storage resources to serve as gap-fillers when their flexibility is most needed. Incentivizing storage (and all resources) in this way will help improve reliability.

The Environmental Sector appreciates MISO’s consideration of these comments and looks forward to continued engagement on these and related topics.

Non-thermal accreditation 

-          The approach of adding back the curtailed wind generation into the actual wind data should not be performed for all instances of curtailment.  There is comparability of the offered MW of thermal generation being used in the Schedule 53 accreditation that the market may not economically dispatch the generation.  If wind is curtailed on an economic basis, it should be added back into the actual wind data.   

-          If the wind is curtailed due to a transmission system limitation, adding the curtailed wind into the actual wind production data creates a higher level of wind output than what the transmission system is capable of providing.  If the curtailment data can includes the distinction of the cause of the curtailment, it would appear to be preferred to not add curtailment into the system for time of transmission system limitations. 

-          Question of how many years of history to use for the ELCC

• Using the three most recent years would be an approach that moves toward showing the more recent system additions and reflecting a more recent impact of the resource.  The annual variations in the wind resource should be assessed to determine the number of years required to represent the intermittent nature of wind.  There are advantages to selecting a larger number of years in order to provide a more stable accredited value from an ELCC standpoint, but the distribution of ISAC values is itself another variable in that it will be using the most recent three years of historic data. 
  • Conclusion: From the information presented, it appears that a longer number of years to establish the ELCC would be a means of establishing a more stable UCAP value.  The desire to show the most recent performance data can be satisfied by using the three historic years to develop the ISAC values that will be used to create the SAC. 

-          Areas of Focus for the September 21 workshop should include the following:

• Trend of ELCC with higher levels of renewable energy – showing the differences in the accredited values from the Case 1 to Case 3 for all the key summaries of the analysis.  
  • There is a central question of how will this method work in the future if the resource portfolio continues to be transformed.
• Show the resource level summary of the cases and the ELCC, ISAC results so the method can be more fully understood. 
• Provide generation owner SAC example spreadsheets so that the impact on accreditation can be more clearly understood before filing the proposed approach. 

-          LMR comments

Continuing the accreditation based on the Firm Service Level is important to provide continued interest from the Minnesota Power Large Power Customers.

The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback on MISO’s evaluation of potential non-thermal accreditation reforms.

MISO Proposal

The EOCs support MISO’s proposal to use an ELCC methodology for determining the total MISO-wide accredited capacity that will be allocated by resource type. With regard to allocating the amount of accredited capacity to individual resources, the EOCs request that MISO provide further analysis to measure unit-level accreditation volatility under MISO’s proposed “RA Hours Method”. As a volatility benchmark, MISO should compare the unit-level accreditation volatility of the “RA Hours Method” to the unit-level accreditation volatility that has occurred historically under the existing wind accreditation methodology. Additionally, the EOCs request that MISO perform analysis to understand how successful the “RA Hours Method” is at predicting future performance during tight margin hours as compared to the existing wind accreditation methodology. For example, MISO could calculate the 21/22 PY unit level accreditation values using MISO’s non-thermal accreditation proposal and then compare those accreditation values to the actual resource performance during the historic tight margin hours that occurred during the 21/22 PY.

Average ELCC vs Marginal ELCC

The EOCs support MISO using an average ELCC approach for determining the fleetwide accreditation of non-thermal resources. As the system operator, MISO’s focus should be on determining the cumulative reliability contribution of each non-thermal resource type. Additionally, an average ELCC approach would be simpler to implement. In contrast, utilizing a marginal ELCC methodology would be overly complex, difficult to implement, and may present fairness issues amongst resource owners depending on implementation details

While expressing support for MISO to use an average ELCC approach, the EOCs believe that there is value in utilizing a marginal ELCC methodology in other settings. For example, the EOCs support planning resource decisions by using a marginal ELCC approach to determine the incremental reliability and economic benefit provided by a new resource.

Other EOC Feedback

• MISO should use the existing annual LOLE study as a guide for how the ELCC study should be conducted. For instance, the LOLE study uses 30 historical weather shapes and is a standalone study (The results from the LOLE study are not influenced by results from prior year studies). MISO could adopt the same approach for the ELCC study by using a large sample size (20 years +) of rolling historical meteorological wind/solar/load data applied to the existing MISO system to calculate ELCC values. This proposed ELCC study would not average results from prior year studies but should still produce stable results from year-to-year due to the large sample size of input data utilized.
• MISO should analyze and seek to understand the impact of the North to South RDT constraint. If the ELCC model power flows between the North and South exceed the RDT constraint, the ELCC results will be less accurate. Given the importance of the RDT constraint and the difference in renewable resource potential in the North vs. the South, MISO should prioritize this analysis.

Alliant Energy is concerned that MISO’s proposal to “Require intermittent BTMG to start providing availability and/or self-scheduled MW in DSRI to give operators visibility into MW available to them at any given time“ is not reasonable.  Small, aggregate intermittent BTMG resources such as solar and wind are not forecasted on such a granular basis and this would become administratively burdensome considering the various locations, small sizes, and technology mix. Instead – MISO should develop its own simplified profiles that can be used as a proxy for these resources.

Similarly, Alliant Energy is concerned that MISO’s proposal to “Provide better transparency by requiring improved locational information in qualification/registration process” would be administratively burdensome for BTMG resources. These resources can be many aggregated resources across an LSE’s service territory.

For wind and solar accreditation methodology, Alliant Energy’s main concern is understanding how accreditation rates vary over time and by zone. MISO has only provided footprint accreditation rates without zonal data and future zonal projections. This additional information is critical for efficient long-term planning.  Moreover, MISO needs to immediately begin discussion on whether solar should be accredited on an average or marginal basis. Here again, understanding the variation is important for efficient long-term planning. We are particularly interested in understanding the marginal vs average solar accreditation rates by zone, and with a projection into the future.

The OMS Resources Work Group (OMS RWG) appreciates this opportunity to provide feedback to MISO on the Non-Thermal Accreditation reforms presented to the Resource Adequacy Subcommittee at its August 24, 2022 meeting.

LMR Strawman Proposal and Design Specifics

The OMS RWG believes that MISO needs to tighten up reporting expectations for LMRs before it would be appropriate to focus on the Demand Side Resource Interface (DSRI) to assess actual resource availability. Several stakeholders have provided examples indicating LMRs might not be reporting full availability, including where availability is listed as 0 when below the fixed load level of the resource. Without fully understanding how LMR owners are reporting availability, it would not be appropriate to compare availability in the DSRI to what clears in the PRA as this is not an apples-to-apples comparison.

Additionally, the OMS RWG disagrees with the approach of expanding the number of hours used for determining the accreditation of LMRs. Under the current design, LMRs can only be deployed during Max Gen Events. Unless this is changed such that LMRs can be called upon sooner, LMR availability during non-Event RA Hours is far less important than availability during Max Gen Events.

The OMS RWG believes that the discussion on aligning LMR accreditation with attributes needed during emergency events should be deferred to the broader resource attribute discussion that the Steering Committee recently assigned to the RASC. Recent LMR changes already emphasize the importance of notification times by reducing the accreditation for LMRs with notification lead-times of greater than six hours.

The OMS RWG supports the MISO proposal to require improved and specific locational information for each LMR during the qualification/registration process.

Lastly, the OMS RWG strongly encourages MISO to allow sufficient preparation time for relevant retail tariffs to be adjusted to accommodate changes to LMR accreditation and/or performance expectations before they become effective.

Wind and Solar Accreditation

At this time, the OMS RWG will not comment on the design considerations and MISO recommendations presented at the August RASC meeting but will instead focus on the areas we believe would be valuable for the September 21^st workshop on non-thermal accreditation.

The OMS RWG requests that the following topics be included in the September workshop discussion:

• Provide plant-level accreditation examples demonstrating how MISO’s proposed methodology would work:
  • Within this example, information on potential year-to-year plant-level volatility would be beneficial.
  • The following information would help us better understand how the ELCC-adjusted by RA hours approach would be implemented:
    • A step-by-step calculation on how the Marginal vs. Average-ELCC would be implemented at the class level.
    • A step-by-step calculation on how the consideration of Schedule 53 at the unit level would consider Seasonal RA Hours and Annual RA Hours.
    • Regional diversity within the ELCC of each resource class:
      • Would it be possible to establish separate classes for wind and solar resources based on which subregion the generation facilities are located? (ex. Solar-North/Central and Solar-South as separate classes)
      • Would it be possible to establish a more granular geographical focus per resource type? The influence of weather on risk events can dramatically vary within zones. A more granular focus on weather-related events could reflect a more accurate representation of each resource’s ELCC.
      • How would separating by subregion impact the portfolio effects?
      • Will the proposed methodology be able to include energy-limited resources as sufficient data becomes available in the future?
      • Within the list of options for consideration on how many historical ELCC values should factor into accreditation, MISO mentions the possibility of using simulated data to generate unique ELCC values for the prompt year. Can this be further explored?
        • More information on how MISO envisions this concept working should be provided at the workshop.
        • It may be helpful for MISO to either:
          • (a) “back-cast” by using their simulation to develop numbers for a prior year and then compare those simulations to actuals; or
          • (b) consider developing these forecasts for a few years and compare forecasts vs. actuals to transparently show the differences and fine-tune the approach before implementation.
          • MISO is considering adding non-thermal resources to Schedule 53 resources. The OMS RWG would like to know more about potentials changes that would be implemented by including non-thermal resources under the class-level categorization of Schedule 53. This includes but should not be limited to:
            • How will non-thermal resources be categorized under the Tier 1 and Tier 2 classes?
            • Will the number of seasonal RA Hours evaluated be 65? If not, how many?
            • For resources with less than 65 seasonal RA Hours, how will the operating margin threshold be calculated and implemented to determine the next tight-margin hours?
            • For resources with a seasonal RA Hour deficiency, what number of annual RA Hours will be considered? (currently 260 Annual RA Hours per each of the three study years)
              • The Alberta Electric System Operator (AESO) reported a potential scarcity risk when utilizing 250 Annual Hours by which certain years’ performance were miscalculated. AESO concluded that the top 1,250 tight-margin hours would better represent the performance for the period under consideration. In their case, a five-year period was considered. We suggest that the top 780 tight-margin hours may be a better representation for the Annual RA Hours.
                • (Capacity Resource Accreditation for New England’s Clean Energy Transition, by The Battle Group)

The third question on slide 28 asks, “How many historical ELCC values should factor into the accreditation for the prompt year?”

• In terms of historical ELCC values, some states see value in shifting towards a 10- to 13-year period rather than a 17-year period to better reflect recent weather risk events and updated fleet information.
• At the RASC meeting, an option was presented that would give higher weighting to recent years. How would the weighting be determined?

This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Resource Adequacy Sub-Committee (“RASC”) on the feedback request made by MISO at the August 24, 2022, meeting of the RASC.[2] AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy resources. AEMA members support the beneficial incorporation of distributed energy resources (“DER” or “DERs”), including advanced energy management solutions, into wholesale markets as a means to achieving electricity cost savings for consumers, contributing to system reliability, and ensuring balanced price formation. These comments represent the collective consensus of AEMA as an organization, although they do not necessarily represent the individual positions of the full diversity of AEMA member companies.

At the August 24^th meeting of the RASC, MISO presented a straw proposal for the accreditation of Load Modifying Resources (LMR) and requested feedback on the proposal. AEMA offers the following comments on MISO’s strawman and LMR accreditation in general: 

• In the presentation at the RASC, MISO proposes to “align LMR accreditation with actual availability during times of need using the Demand Side Resource Interface (DSRI)” and to “require intermittent BTMG to start providing availability and/or self-scheduled MW in DSRI to give operators visibility into MW available to them at any given time.” While this suggestion appears to align with the proposed seasonal accreditation approach, AEMA would caution MISO to avoid adding increasing levels of complexity to the ongoing participation of these emergency only resources. Currently, a resource must update a daily availability within the DSRI, including any self-scheduled MWs. This is a significant barrier for very small resources that only have limited revenue opportunities in MISO but face significant performance penalties for any “failure to perform.” 

MISO should examine the potential for new participation models that bridge the difference between emergency only and full DA and RT market participation. For example, could there be a resource that MISO activates at an earlier stage of an event, before an emergency is declared? This might be like an EDR that is economically dispatched and would potentially be available as non-emergency resource. While some resources are only accessible in an emergency, that may not be true of all resources. A survey of resources might indicate how many existing resources could respond outside of an emergency.  

• MISO also proposes to “Align LMR accreditation with attributes needed during emergency events (e.g., reduced notification times are more valuable).” While this might help with resource availability and allow operators greater flexibility in addressing emergencies, MISO should also consider the limited history of LMR deployments, particularly following recent performance requirement changes. For example, MISO implemented multiple changes that took effect in 2022, but has no history on the impact on availability and performance as LMRs have not been dispatched so far this year. While historical performance may be appropriate for other resource types, MISO should look to other mechanisms to consider how to accredit LMR capacity value. 

• Historical MCS data is not a full and accurate reflection of LMR availability. For example, duel enrolled LMR/EDR resources manage their availability through EDR offers, rather than as an LMR in the MCS/DSRI portal. Prior to 2021/2022, LMRs were only obligated to perform in the summer to achieve full accreditation. Multiple LMR deployments occurred outside the summer period in the history of LMR deployments. Additionally, the MISO analysis failed to account for self-scheduled BTMG/DR running during peak hours, or market participants that have self-scheduled their own LMRs for their own reason. Without accurately understanding these factors, the historic data cannot and should not be utilized to change capacity accreditation for LMRs. As MISO considers any new accreditation methodology for LMRs, MISO should ensure that the methodology is commercially reasonable and does not rely on historical data provided under alternative Tariff language that had different sets of rules and financial incentives. 

• Under any resource accreditation methodology, MISO should examine resource specific or Market Participant specific derates rather than resource wide averages.

• AEMA requests that MISO also compile and maintain a history of LMR events that is publicly available for entities considering registration of LMRs. This history should include date, time of notification, time of deployment, duration of deployment, and cause of the event.

• Finally, MISO proposes to improve “transparency by requiring improved locational information in the qualification/registration process.” AEMA is curious to understand what additional information may be needed and how that information would be utilized. Will this become part of the system modeling process? 

• MISO noted that it would be discussing design specifics with stakeholders in the next few months. In recent years, MISO has made multiple changes to the performance requirements of LMRs, including year-round availability, shorter notification times, and increased number of responses. Instead of continuing to increase the performance requirements, MISO should consider incentivizing resources to transition from LMR status to registration as an asset. This might be a Demand Response Resource (DRR) asset or part of an aggregation of Distributed Energy Resources (DER). Creating a new market participation option that bridges the difference between DA/RT participation and Emergency Only participation could go a long way to incentivizing resources to be more available without creating increasing levels of performance that could drive some resources to not participate at all. There should remain a place in the MISO construct that allows for emergency only response.  

AEMA appreciates MISO’s consideration of these comments as part of the examination of resource accreditation issues within MISO. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to discuss with AEMA members. 

Respectfully Submitted, 

Katherine Hamilton
Executive Director, Advanced Energy Management Alliance
Katherine@aem-alliance.org
202-524-8832 

or

DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052

The Coalition of MISO Transmission Customers supports the comments submitted today on behalf of the end use customer sector. Additionally, we recommend that MISO consider performance testing for load modifying resource capacity accreditation, rather than reliance on data from its DRIT. For example, in PJM if there is not an actual event during summer months that can be used to verify available capacity demand response resources are required to conduct a one hour performance test in September. 

Non-Thermal Accreditation

• Duke generally supports the application of SAC (i.e., “RA Hours Method”) to renewables, with some conditions
• Duke opposes the use of AAOC to backfill deficient seasonal Tier 2 hours for renewables – the sensitivity to seasonal performance of renewables is simply too high to accept annualization of any component of accreditation.  MISO downplayed this issue for thermal resources, but no argument can justify the intermixing of seasonal performance for renewables.  For example, most annual Tier 2 hours are in the summer, where solar contribution to peak is highest.  It is inappropriate to use such a summer weighted AAOC to backfill Tier 2 hour deficiencies in the winter where solar otherwise has a very minimal contribution to peak.  This will result in a material over-accreditation of solar in the winter, which only compounds the problem to the extent that AAOC tends to under-accredit thermal resources in the winter for the exact opposite reason (thermal resources generally have higher ICAP in the winter, which gets diluted by a summer-weighted AAOC).  The use of AAOC in this manner is unfair and inequitable across the resource types.  Many stakeholders provided many alternatives to AAOC during the thermal design phase.  MISO should go back to the drawing board on AAOC and develop a method that ensures the integrity of the seasonal data, especially for renewables, but for thermal resources as well.  Duke may oppose the application of SAC to non-thermal resources if MISO continues the use of AAOC, as AAOC is a fatal flaw in the design that is untenable for the very seasonally sensitive renewable resources.
• Duke generally accepts the concept of using “Actual injections plus curtailments” for wind and solar as the equivalent of the thermal hourly offer
• Duke generally accepts the concept of the “System_ELCC/System_ISAC ratio” for wind and solar.  However, additional clarity is required.  Does MISO intend to keep the ratios separate for wind and solar, or combine all non-thermal ELCC and ISAC together into one single ratio?  Also, would MISO intend to ever intermix the thermal and non-thermal ratios into one single ratio for all resources?
• Duke commends MISO for recognizing the failure of the outage exemption process to fairly and appropriately consider exemptions for planned derates (“Market Redefinition:  Accreditation Reforms for Non-Thermal Resources”, slide 29, lower right table cell, “Same, look at adding exempt derates for all Schedule 53 resources”), and encourages MISO to remedy this shortfall as absolutely soon as possible, preferably for consideration in the upcoming 2023-2024 plan year SAC computation.

 Non-Thermal Accreditation regarding LMRs specifically:

1. Duke is supportive of potential revisions to LMR availability reporting in the DSRI tool, specifically the potential inclusion of new data fields to assist with accurate reporting of LMR availability.  As noted during the 8/24 RASC meeting, Duke would ask MISO consider carefully any potential use of the “Self-Scheduled” field in the DSRI to track LMR capability that has been lost due to weather or reduced process load and the potential interactions with Settlement processes.  A separate data field may be required to distinguish between DR events that have truly been “self-scheduled” and decreases in availability due to other conditions.
2. Duke is supportive of the steps taken by MISO to revise the LMR accreditation process to better align PRA values and those tracked in the DSRI, including the strawman proposal presented during the 8/24 RASC meeting.  Generally, we are supportive of ensuring alignment between PRA and DSRI values (during system/seasonal peak conditions) as well as revising the value for quicker-responding LMRs and providing locational information, so long as this information is not overly burdensome.  On all areas, Duke looks forward to being able to provide feedback on a more detailed proposal from MISO.

It appears that MISO’s proposal on LMR accreditation would decrease the capacity accreditation of BTMG or LMR generation that MPs use to meet their demand. If MPs are not given credit for BTMG that is being self-scheduled during tight hours, then the MP has a higher capacity obligation and cannot satisfy its requirements with resources it put in place to meet its demand. Either the energy needs to be netted out on the capacity obligation and transmission side, or the MP should get the capacity benefit of having the resources that it is running to meet its demand. MPs should get capacity credit for all of their DSRI MW for generating units, whether they are self-scheduled or available to MISO. Otherwise, MISO would be over-procuring capacity. The generation is being used to meet the MP’s demand, whether it is self-scheduled or available to MISO. Maybe a distinction needs to be made between BTMG or LMR generation units and interruptible loads.

Xcel Energy appreciates the opportunity to provide feedback regarding MISO's proposal for accrediting wind and solar resources and initial design considerations.  We support MISO's proposal to calculate capacity accreditation for wind and solar using ELCC at the class level and allocation to individual units based on RA hours.  However, we feel there needs to be an intermediate allocation between the resource types to account for the interactive effects and the significant difference in total capacity between wind and solar.  One method to do this could be to use the "Delta Method" as proposed by E3, but we are open to other ideas that MISO may have. 

We strongly recommend that MISO use average ELCC for capacity accreditation but provide forward looking marginal ELCC values by resource type to use for resource planning.  MPs need the forward looking marginal ELCC values as intermittent and energy use limited penetration increases to guide appropriate capital investment decisions.

 We also strongly believe that BTMG solar should be included with utility scale solar in the ELCC calculation as it has a definite impact to the value of solar on the system.  BTMG solar should be accreditation using the same methodology as utility scale solar.

 At this point in time, we support using the structure of calculating the RA hours based on Schedule 53.  However, we are undecided as to whether the allocation should be solely based on Tier 2 hours or a split between Tier 1 and Tier 2.  We would appreciate MISO's evaluation of looking at the allocation using both of these approaches.  We will note that as the system evolves, the spread of high-risk hours may increase to the point that more than 3% of the hours should be considered high risk.  This will become evident as the number of hours that fall below the 25% margin threshold trends upward. 

Regarding the number of historical ELCC values to include in the calculation, we note that climate impacts and generator upgrades will impact the profiles.  Therefore, we believe a balance of sufficient data that is the most representative of current hourly profiles would be to cap the data at some point between five and 10 years. 

Comments on MISO’s Non-Thermal Accreditation Presentation

August 24^th RASC

Clean Grid Alliance appreciates the work MISO has completed to date to consider and evaluate various potential modifications to the accreditation methodologies used for wind and solar.  We agree that resource adequacy is important to ensuring system reliability, and we are committed to working towards a consistent accreditation methodology for all resource types, that fairly values the contributions of each resource towards meeting the capacity demands on the system in high-risk hours.  In these comments we respond to MISO’s request for input, pose a number of clarifying questions we hope that MISO can address, and include requests for MISO to provide additional analysis during the September workshop.  Given that the recent proposed wind/solar accreditation approach was not presented among the options in earlier meetings, we urge MISO to allow for sufficient time to understand its proposed approach and how it compares both to thermal accreditation and the other accreditation methodologies MISO was considering prior to proposing this new approach presented on August 24^th.  Another workshop will very likely be needed and we urge MISO to put one on its calendar now.

How should an RA Hours approach be applied to determine the relative capacity accreditation for individual units? Should wind and solar be added to the definition of Schedule 53 Resources?

First, we appreciate that MISO seems to be trying to bring non-thermal and thermal accreditation closer together with its proposal to start with the Schedule 53 RA Hours approach[1].  We are, however, concerned, and unclear about the ELCC adjustment to the wind and solar accreditation, and request MISO provide more clarity on this approach, including examples that show how non-thermal accreditation and adjustment will work and how this compares to thermal accreditation and adjustment.

We recommend that MISO employ only the RA hour accreditation approach for standalone wind and solar. This will accredit all generating resources in the same way based on their availability at risky times.  MISO’s proposed method (from the 8/24/2022 presentation), which distributes total system-wide ELCC-based MWs over resources pro rata based on their historic RA Hours performance, is still a blended approach and conflates risks that can be addressed separately in the planning and operating horizons.  We request MISO address the following aspects of the RA Hours/ELCC approach they propose to apply to accreditation for wind and solar and whether this would be applied in the same way as they are for thermal resources.

• Adjustment of RA Hours accreditation for both thermal and wind and solar resources
• Tier 2 vs Tier 1 hour weighting in the historic performance calculation for each resource
• Exemptions for outages in the historic performance calculation
• Exemptions for outages in instant-year performance evaluation (and need for replacement capacity)
• Annual RA hour replacement for a season with too few historic RA hours
• Number of RA hours appropriate for wind & solar, is this the same as thermals?

MISO should treat renewables as Schedule 53 resources.  Using ELCC to adjust wind and solar, will in most cases result in a decrease in the capacity accreditation from the RA Hours analysis.  On the other hand, the adjustment of thermal resource RA Hours accreditation in the SAC construct increases the accreditation of thermal resources.  If MISO wants to include ELCC in its capacity accreditation, it needs to do so on a consistent and comparable basis. 

How should a probabilistic approach to class level accreditation be calculated? Should MISO utilize a marginal or average ELCC approach?

If ELCC is used, we strongly support the use of average ELCC for capacity accreditation of all existing wind and solar resources in the prompt year.  This approach will treat all resources comparably when considering the MWs of capacity they have available to meet load in any high-risk hour.  Using marginal ELCC would suggest that older resources on the system offer more capacity than new resources in any hour, even though each MW provided in any hour should be treated the same.  Marginal ELCC does have a place, but it should be used by utilities and states making decisions about future resource investment.  Marginal ELCC will give a better sense of the incremental capacity value of adding any new resource to the overall resource mix.  

How many historical ELCC values should factor into accreditation for the prompt year?

If MISO uses ELCC, using three years of ELCC analysis seems appropriate to best align with the fact that MISO uses three years of RA Hours for thermal resources, and we assume will do the same for non-thermal resources.  We understand that this may lead to greater volatility, but it would also better capture the capacity contributions of the most recent fleet of resources, and any improvement in performance they have been able to achieve. 

Suggestions for what to address during the Sept workshop:

• First, as noted above, provide analysis of the capacity accreditation results for MISO’s recently proposed approach for wind/solar accreditation as it compares to the other approaches MISO has analyzed so far.
• Show analysis of how the proposed ELCC adjustment for wind and solar compares with the adjustment for thermal resources.
• Explain how ELCC analysis would work for thermal plants.  If MISO is committed to working towards comparable treatment for all resource types, it should ultimately use either ELCC or the LOLE adjustment for all resource types.  We understand that NYISO uses ELCC for thermal plants.  We urge MISO to have a NYISO expert present on how they use ELCC for thermal resources at the September workshop.  If other regions also use ELCC for thermals, bringing those examples into the discussion would be helpful as well.
• Has MISO considered evaluating the fleet-wide ELCC value on a more granular basis than footprint wide?  We request MISO provide some analysis on how ELCC evaluated on a subregional or LRZ basis would compare to a footprint-wide ELCC value.
• On slide 18 of MISO’s presentation, MISO suggests that the RA Hours approach may miss the impacts of extreme weather.  And yet MISO says that its proposed wind/solar approach, which is based on the RA Hours approach can address a wider range of events and is better aligned with the recently approved thermal accreditation approach.  Please explain this, especially since the thermal accreditation uses an RA Hours approach, but uses a different method for adjusting that result to the SAC. 

Further Comments:

• If MISO ultimately uses ELCC in non-thermal accreditation, we offer support for MISO’s proposal to use a portfolio approach to ELCC rather than an individual resource ELCC.  The portfolio approach does a better job of estimating the ELCC of resources in the reality of the resource mix.
• Finally, we urge MISO to implement a simpler approach to accreditation for all resource types.  It is challenging to explain this approach of adjusting thermal or non-thermal accreditation after using the RA Hours approach to come up with each resource’s contribution to capacity in high-risk hours, especially given the many potential exemptions.  An RA Hours approach for all resources, without this adjustment, and without the various exemptions, would be much easier to explain to commissioners and other decision makers who are concerned about ensuring resource adequacy.

Comments

of the

Association of Businesses Advocating Tariff Equity (ABATE),

Illinois Industrial Energy Consumers (IIEC),

Louisiana Energy Users Group (LEUG),

Texas Industrial Energy Consumers (TIEC),

Coalition of MISO Transmission Customers (CMTC),

Midwest Industrial Customers (MIC),

and

NIPSCO Large Customer Group (NLCG)[1]

Regarding

RASC: Non-Thermal Accreditation

(RASC-2019-2, 2020-4) (20220824)

September 7, 2022

ABATE, IIEC, LEUG, TIEC, CMTC and MIC, as representatives of the End-Use Customers (EUC) Sector, and NLCG appreciate this opportunity to provide comments to MISO.

At the August 24, 2022 meeting of the MISO Resource Adequacy Subcommittee (RASC), MISO presented accreditation reforms for non-thermal resources.  Stakeholders were asked to provide input on a number of matters including MISO’s LMR capacity accreditation strawman proposal and design specifics presented in Slide 10 of MISO’s August 24^th presentation on non-thermal resource capacity accreditation.

Slide 10 of the August 24^th presentation indicated that the LMR capacity accreditation proposal would consider:

• Number of hours per season

• Measuring availability for LMRs including intermittent BTMG

• Emergency Demand Response (EDR), Demand Response Resource (DRR) and LMR overlaps

• Transmission losses & PRMR add-back

• Intermittent BTMG forecasting

• Reliability value of notification times

• Process for the collection of accurate electrical locational information

We would note that MISO has not fully outlined what it intends with respect to all of the above issues.  For example, MISO has not identified what it intends with respect to the existing transmission losses and Planning Reserve Margin add-back that currently applies to LMR Demand Resources.  Nor has MISO done so with respect to the number of hours per season.

With respect to the remainder of the above items, we addressed them in the extensive comments that the End-use Customer Sector submitted to MISO on August 3, 2022.  Those comments can be found at:

https://cdn.misoenergy.org/End%20Use%20Sector%20Comments%20on%20RASC%20LMR%20Accreditation%20Feedback%20(RASC-2019-2%202020-4)%20(20220713)625854.pdf

In a nutshell, those comments indicated:

• Self-Scheduled MW from the MISO Demand Side Resource Interface (DSRI) must be included with Available MW in order to properly compare the capacity provided by LMR Behind the Meter Generation (BTMG) and LMR Demand Resources that do not use the Firm Service Level option versus the amount of capacity accredited to them.

• The proper assessment of the capacity provided by LMR Demand Resources using the Firm Service Level option is to examine their availability to curtail down to their Firm Service Level – information that is not currently collected in the MISO DSRI.

• There should not be any further restriction at this time on the allowed notification times for LMRs under the MISO Tariff or any changes to how notification times currently affect capacity accreditation for LMRs under the MISO Tariff.

• Further examination should be made with respect to MISO’s ability to issue LMR Scheduling Instructions during Capacity Advisories, in advance of a Maximum Generation Event at Step 2a or higher occurring, when there is a very high likelihood of a Maximum Generation Event at Step 2a or higher occurring.

• There should be an examination of whether Scheduling Instructions for LMRs should be allowed to be issued to commence at the start of a period of very high likelihood of a Maximum Generation Event at Step 2a or higher occurring.

• Consideration should be given to whether MISO has a need to establish an additional type of operating reserves, specifically, additional operating reserves (to supplement the new Short Term Reserves product) that would have a notification time that falls somewhere between that required for Short Term Reserves and that typically provided by LMRs and non-quick start generation that is offline.

• MISO should collect, upon registration, the CPNode of each LMR in order to get accurate electrical location information.

• MISO should not try to obtain electric location information on a more granular basis for LMRs than the CPNode level because LMRs can consist of the aggregation of load curtailment spread out over a wide geographic area within a given Local Balancing Authority (LBA) Area through utility or Aggregator of Retail Customer load management systems.

• MISO should collect and record information in the MISO Communication System (MCS) on the forecasted hourly generation level of LMR BTMG that is intermittent.

Our detailed comments from August 3^rd continue to apply.

During the August 24^th meeting, MISO appeared to suggest the following:

• Available and Self-Scheduled MW values from the DSRI during Resource Adequacy hours should be used for LMR capacity accreditation.

• LMR Demand Resources, using the Firm Service Level option, should in the DSRI report the portion of their non-firm demand that is not expected to be present in a given hour as Self-Scheduled MW.

Given the real power testing requirements that already apply to LMRs as well as the severe penalties for non-performance that apply to LMRs, but do not to Generation Resources, we do not believe it is necessary to base the capacity accreditation of LMRs on their availability as reported in the MISO DSRI and we oppose MISO’s pursuit of such an approach.  However, if despite our opposition, MISO continues to pursue potentially using DSRI information during Resource Adequacy hours for the capacity accreditation of LMRs, as a minimum, the following must be addressed:

1. Such capacity accreditation should be based on the sum of Available MW and Self-Scheduled MW (or the sum of Available MW and non-firm demand that is already expected to not be present in the case of LMR Demand Resources using the Firm Service Level option), not just Available MW alone.      
2. The term “Self-Scheduled”, as it applies to LMRs, should be modified or changed such that, in the case of LMR Demand Resources using the Firm Service Level option, it includes the reporting of non-firm demand that is already expected to not be present in a given hour.
3. The need for LMRs of all types to report “Self-Scheduled” MW in the MISO DSRI should be clearly communicated to all Market Participants and reflected in MISO’s Business Practice Manuals.
4. Sufficient time should be allowed for all LMRs to build up at least 12 months of Self-Scheduled MW data in the MISO DSRI prior to DSRI data being used as a basis for capacity accreditation for LMRs.
5. Provisions should be developed to address the treatment for new LMRs and LMRs that have an increased or decreased level of MW participation versus the period reported in the DSRI.

Thank you for providing us an opportunity to provide these comments.  If it would be of help, we would be glad to discuss any of the above comments further with MISO.  We would also be glad to make a presentation at the RASC with respect to any of the above to help both MISO and its stakeholders better understand our comments.  With respect to either, please do not hesitate to contact any of the following representatives:

Jim Dauphinais

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(636) 898-6725

jdauphinais@consultbai.com

Ali Al-Jabir

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(361) 994-1767

aaljabir@consultbai.com

Kevin Murray

McNees Wallace & Nurick LLC (for CMTC)

(614) 719-2844

murraykm@mcneeslaw.com

Kavita Maini

KM Energy Consulting, LLC (Consultants to MIC)

(262) 646-3981

kmaini@wi.rr.com

     Michigan Public Power Agency (MPPA) welcomes this opportunity to provide formal feedback on MISO’s LMR strawman proposal. We strongly encourage using the same RA Hour regime approved by FERC in MISO’s SAC filing (Docket ER22-495). First, it offers a modicum of RA consistency across resource classes. Also, emergency resources such as LMR already face unique, substantial penalties for shortfalls during Maximum Generation Emergency Events, so reducing the number of RA Hours used only for LMR accreditation appears discriminatory.
     As stated in MPPA’s feedback to MISO’s request from the July’22 RASC meeting, MISO should NOT further decrease resource availability by further lowering the PRA qualifying Notification Time. As to the reliability value of notification time, which I take to mean tiered accreditation, how does MISO propose to establish it empirically? MPPA would like MISO to consider the reliability value of the already available Capacity Advisory declaration, as well as additional changes to the Market Capacity Emergency Procedure, to more effectively extract reliability value from LMR in the operating horizon.
     As also stated in MPPA’s previous feedback, we support including specific LMR Locational Information, such as the physical mailing address, in Module E Capacity Tool (MECT) registration. It would then fall to MISO’s expertise to map that information to their network model.

Wolverine supports MISO’s direction to improve the LMR accreditation methodology in parallel with the non-thermal resource accreditation changes whereby all capacity resources will be treated consistently and comparably. MISO’s data (which ranges from 68%-95% BTMG availability and 44-79% DR availability, depending on the season) provides enough evidence to show that LMRs are not as available as they need to be. The result is a capacity construct that risks reliability by over accrediting resources (physical impact) and pays resources that do not deliver (economic impact). 

This LMR over accreditation situation is not new and while MISO is slightly increasing the annual dispatches by establishing seasonal dispatch requirements, it is still not comparable to other resources that make themselves available around the clock. Given the focus on availability for thermal and non-thermal resources, it is imperative that the last remaining set of capacity resources (LMRs), a.k.a. last resort resources, also transition to an availability-based accreditation. Doing so will provide comparable treatment across all capacity resources and ensure that all resources being relied upon and paid for capacity provide the same level of reliability support.

Vistra Corp. (“Vistra”) appreciates MISO providing stakeholders with the opportunity to submit feedback on the proposed accreditation reforms for non-thermal resources. Vistra looks forward to the September 21 Non-Thermal Accreditation workshop which we believe will be critical for providing stakeholders with additional clarity on MISO’s recommended accreditation approach of ‘ELCC adjusted by RA Hours’ for wind and solar resources. Vistra is reserving judgment on the various design elements of MISO’s recommended approach until additional information is made available at the September 21 workshop. During that workshop, there are several topics that Vistra respectfully requests MISO address, each of which will assist stakeholders in determining if MISO’s non-thermal accreditation proposal ensures that the accredited capacity values of wind and solar resources correctly reflect the capability and availability of those resource during the periods of highest reliability risk.

Accreditation of New Solar Resources

Vistra requests that MISO clarify how they will determine the accreditation values of new solar resources. MISO’s current Resource Adequacy Business Practices Manual provides that new solar resources with less than 30 consecutive summer days of data will be accredited based on the solar class average XEFOR for the initial Planning Year. If the new solar resource has at least 30 consecutive summer days of data, the average historical summer output from the Commercial Operation data will be used to determine the GVTC.  In year 2, MISO then uses the average historical solar summer output from Year 1 to determine the solar resource’s GVTC; in year 3, MISO uses the average solar historical summer output from Years 1 and 2; and in year 4, MISO uses the average historical summer output from Years 1, 2, and 3.

 With FERC’s recent approval of MISO’s Seasonal Resource Adequacy Proposal, does MISO propose utilizing a similar concept that is now adjusted by seasonal output? For example: if a new solar resource has less than 30 consecutive days of data for the March-May seasonal period, will the new solar resource be accredited based on the solar class average XEFOR for March-May? Any information on how the proposed “class level” and “unit level” approach will impact MISO’s treatment of new solar resources is appreciated.

Numerical Spreadsheet Example to Illustrate Conversion of Class-Level Calculations into Unit-Level Accreditation

Vistra appreciated the spreadsheet example MISO previously provided that illustrated how the RA hour method would build up into a unit-level capacity accreditation.  We believe a similar spreadsheet example would provide additional insight into how the RA hours will be used to convert a class-level capacity accreditation into a unit-level accreditation.

 MISO’s Suggestion to Extend Schedule 53 to Wind and Solar Resources

As discussed during the August 24 RASC meeting, Vistra believes the unit level proposed accreditation calculation for solar resources, utilizing a tiered weighting of 20% for Tier 1 non-RA hours and 80% for Tier 2 RA-hours, requires further examination: specifically, the Tier 1 non-RA hours. Stakeholders would benefit from an improved understanding of the impact the Tier 1 non-RA hours calculation has on solar resource accreditation during the evening hours when solar resource are unavailable. Vistra is not yet suggesting the elimination of the Tier 1 non-RA hours for solar resource unit level accreditation, instead we would like to see data or a scenario that clarifies what impact Tier 1 non-RA hours has on solar accreditation.

Vistra requests that for the upcoming Non-Thermal Accreditation workshop, MISO develop a solar accreditation comparison or scenario that focuses on unit level solar performance utilizing the 80%/20% weighted average RA Hours method that MISO recommends. This would help stakeholders and MISO better understand the impact Tier 1 non-RA hours have on unit level solar accreditation. For example: one unit level scenario could include the Tier 2 RA hours using the 80% weighted average along with the 20% Tier 1 non-RA hours and include all non-RA solar hours in the Tier 1 calculation. The second scenario would include the Tier 2 RA hours using the 80% value, along with the 20% Tier 1 non-RA hours, but would exclude from the Tier 1 calculation, hours during the evening when solar resources are completely unavailable. Vistra recommends using the summer months (June-August) for developing this comparison. If MISO determines that the inclusion of the evening, non-RA solar hours, in the Tier 1 calculation significantly impacts the accreditation of solar resources, it may be worth considering an adjustment to the Tier 1 non-RA calculation that removes these evening non-performance hours from the 20% calculation.

 Utilization of LOLE in MISO’s Recommended Unit-Level and Class-Level Calculations

Vistra seeks clarification on how LOLE modeling will be incorporated into MISO’s recommended unit-level and class-level non-thermal accreditation calculations. As previously discussed, and acknowledged by MISO, historical non-thermal RA Hours and LOLE hours generally have little overlap. However, it appears from MISO’s recent comments and presentations regarding non-thermal accreditation, that MISO still plans to utilize some type of LOLE analysis in the non-thermal RA Hours (unit level) and portfolio ELCC (class level) calculations. Additional information on how LOLE calculations will be incorporated would be helpful.

 Request for Wind and Solar Non-Thermal Accreditation Scenarios for September 21 Workshop

As discussed during the August 24^th RASC meeting, it would be helpful if MISO developed several scenarios of actual non-thermal accreditation values that may result from MISO’s class level and unit level recommended approach. For example, it would be helpful to develop a solar and wind scenario with a low, class level performance, but a high, unit level performance. In the inverse, a solar and wind example with low, unit level performance, but a high, class level performance would be beneficial. It would also help if the examples or scenarios include the data and process MISO utilized to arrive at the solar and wind non-thermal accreditation values.

• Input on MISO’s LMR strawman proposal and design specifics presented in Slide 10

1.  As described in its presentation to the July RASC meeting, MISO’s focus on potential changes to accreditation of LMRs is premised on the notion that there are substantial disparities between the LMR capacity that clears the capacity auction and the capacity that is actually available to operators during capacity-shortage conditions.  WPPI and other stakeholders raised a number of questions about the numbers presented by MISO in July.  MISO has addressed some, but not all, of these concerns in the updated tables presented at slide 6 of the August presentation.  WPPI would like MISO to do more to demonstrate the existence of a substantial disparity, or the inadequacy of current accreditation methods, before turning the attention of RASC to potential further LMR accreditation changes. 

Specifically, we find the Demand Resource (DR) data on slide 6 of the August presentation inadequate to demonstrate an accreditation problem, for the following reasons:

• The numbers MISO reports for self-scheduled Demand Resources (DR) are plainly far too small to provide a proper accounting of Firm Service Level Demand Resources.  As stakeholders noted during the August meeting, they interpret self-scheduling as action taken in response to a directive from the entity that registered the LMR, and not as including loads below the firm service level because of retail-customer operations or relatively mild weather (this is also true for WPPI).  Accordingly, MISO’s numbers, updated with self-scheduling adjustments, still appear to not account properly for Firm Service Level Demand Resources. 
• Dual-registered LMR DR & Emergency Demand Response (EDR) resources typically report real-time availability as EDRs, not as LMRs.  MISO must account for such resources in some manner in order to make a proper case for changes to DR accreditation.  At a minimum, MISO should provide the total quantity of dual-registered resources so as to delineate the maximum affect that dual registration could have.
• Finally, RA Hours range from peak-demand hours to hours with very substantial capacity margins, the latter of which may reflect relatively mild weather conditions.  Accordingly, MISO should report not only average DR availability but also some indication of the range of availabilities in the data or of the availability levels during peak-demand conditions.

2.  WPPI reiterates that intermittent BTMG LMRs are already accredited on the basis of actual historic availability.  Before proceeding any further to consider changes to accreditation of these resources, MISO should explain to stakeholders why the existing accreditation approach is inadequate.  We are open to providing MISO with location and generation-output data for intermittent BTMG, or considering forecasting of intermittent BTMG, though we would ask MISO to better substantiate the need for these enhancements. 

3.  MISO also asks, at slide 10, about requirements for the number of hours per season and notification times.  MISO has already made adjustments to both types of requirements in the recent past.  Consistent with our comments provided in response to MISO’s LMR accreditation feedback request from the July RASC meeting, we would like to have MISO report on its experience providing advance instructions to longer-lead-time resources before proposing further changes to maximum LMR notification lead times.  Similarly, the next step in any further modification to minimum seasonal deployments (or hours) should be a detailed explanation from MISO as to why such modification is necessary.

• Input on the following for wind and solar accreditation:
• MISO’s recommendation to accredit wind and solar resources based on performance during RA Hours and adjust cumulative unit accreditation to a class capacity value that is derived from a probabilistic method

4.  WPPI is comfortable with the general approach described by MISO at the August RASC meeting.  We do, however, find MISO’s choice of how to describe this approach confusing.  The proposed approach is quite similar to the existing wind accreditation approach, which MISO has always described as consisting of a MISO-wide ELCC calculation followed by an allocation of MISO-wide ELCC to individual resources on the basis of historic availability during specified peak-demand hours.  Accordingly, the logical way to describe the new approach is the same, but with specified peak-demand hours replaced with RA Hours.  Instead, MISO chooses to describe this as an RA Hours accreditation with a subsequent adjustment based on MISO-wide ELCC.  One suspects that MISO is doing so because it wants to emphasize similarity to the existing Schedule 53 methodology.  We would ask MISO to prioritize consistency with past description and clarity for affected stakeholders over efforts to highlight similarity to Schedule 53.

• Design considerations and recommendations presented in Slides 28-31

5.  As we have previously communicated to MISO, WPPI believes it is inappropriate to include all-hours availabilities with RA Hour availabilities in accrediting non-thermal resources.  This approach is reasonable in the case of accreditation of thermal resources, in order to reduce volatility of accreditation results for resources that may have long planned outages.  It is not appropriate for use in the distinct proposed accreditation methodology for a distinct type of generation resource.  Specifically, we expect wind and photovoltaic generation to have a distinct diurnal variation with a statistically significant correlation to incidence of RA Hours.  MISO appears to be proposing to include all-hours availability in non-thermal accreditation for the sake of superficial consistency with the filed SAC methodology.  MISO also argued that inclusion of all-hours availability will have little impact since it will be applied similarly to all affected resources.  Neither of these appears to be an adequate reason for including all-hours availability in non-thermal accreditation. 

6.  We recommend that MISO ensure that a sufficiently long historical period is used for non-thermal accreditation.  We have seen significant year-to-year variation in wind ELCC, and we expect that several years’ of data will be required to provide appropriate capacity values.  On the other hand, we do see that the current wind accreditation methodology may retain historical data for too long.  Specifically, ELCC curves derived from historical data in past years (such as those shown in Figure 2-3 of the latest wind & solar accreditation report) may no longer be reflective of the current resource mix, state of intermittent-generation technology mix or load pattern.  Applying these offsetting considerations, we would recommend using a historical period of 5-10 years.  We are open to weighting more-recent data somewhat more heavily or phasing older data out. 

7.  We are not persuaded that simulated historical data has a role in accreditation.

8.  WPPI is content to retain uniform average-value accreditation for wind and for solar.  Even if marginal considerations are introduced, however, we take the position that total accreditation must be equal to total resource-adequacy value.  We anticipate that introducing marginal considerations could be complicated and take considerable MISO and stakeholder time and effort.

• Areas of focus for the September 21 workshop

9.  WPPI suggests that all of the non-thermal accreditation topics above merit consideration at the planned workshop. 

Finally, we stress that MISO should not rush consideration of non-thermal and LMR accreditation changes to fit a preconceived schedule, but rather should allow the stakeholder process and accreditation-methodology development process to reach a reasonable conclusion before moving to file at FERC.

AMP and MPPA support WPPI's feedback.

Also, AMES, AMP, IMEA, and MRES support MPPA's feedback.

I'd be happy to discuss.

David Sapper

dsapper@ces-ltd.com

LBWL supports MPPA's feedback.

Alcoa Power Generating, Inc. (APGI)

Feedback on

RASC: Non-Thermal Accreditation (RASC-2019-2, 2020-4) (20220824)

September 07, 2022

During the August 24, 2022, Resource Adequacy Subcommittee (RASC) meeting, MISO requested feedback on their Load Modifying Resource (LMR) Accreditation strawman.[1]  

As a MISO Market Participant and Load Serving Entity with LMRs in the MISO MECT, Alcoa Power Generating Inc (APGI) has specific interests in the accreditation process for LMRs.

APGI offers the following feedback and suggestions:

• In the presentation to the RASC, MISO proposes to "align LMR accreditation with actual availability during times of need using the Demand Side Resource Interface (DSRI)" and "require intermittent BTMG to start providing availability and/or self-scheduled MW in DSRI to give operators visibility into MW available to them at any given time." APGI has a large BTMG that participates as LMRs and provides updates to the DSRI. In addition, APGI updates the status of the BTMG to the MISO CROW system and reports the information in NERC GADS. This creates double reporting requirements for some BTMGs. MISO should consider streamlining the process to separate BTMGs that already provide status updates through CROW and are accredited based upon GADS data. These resources already receive derates based upon overall availability and should be treated like other Generation Resources. This would reduce some of the burden for participation in the MISO markets.

• MISO should examine the potential for new participation models that bridge between emergency only and full DA and RT market participation. For example, could there be a resource that MISO can activate at an earlier stage of an event, before an emergency is declared?  While some resources are only accessible in an emergency, that may not be true of all resources. For example, the APGI BTMG would potentially be available for MISO to send dispatch instructions to, when the generators are not on outage. A survey of resources might indicate how many of these resources could respond outside an emergency.

• MISO also proposes to "Align LMR accreditation with attributes needed during emergency events (e.g., reduced notification times are more valuable)."  While this might help with resource availability, MISO should also consider the limited history of LMR deployments, particularly following recent performance requirement changes. For example, MISO implemented multiple changes in 2022, but has no history on the impact on deployment, since there have been no deployments this year. Increasing the performance requirements could reduce what resources are available for MISO to access. LMRs should not have the same performance requirements as registered Generators and DRRs because they are inherently different in their operation, compensation, and penalty structure for non-performance.

• Finally, MISO proposes to improve "transparency by requiring improved locational information in qualification/registration process." APGI in interested in understanding what the development would entail and the implications to utilization of LMRs.

• MISO noted that it would be discussing design specifics with stakeholders in the next few months. In recent years, MISO has made multiple changes to the performance requirements of LMRs, including year-round availability, shorter notification times, and increased number of responses. Instead of continuing to increase the performance requirements, MISO should consider incentivizing resources to transition from LMR status to registration as an asset. This might be a Demand Response Resource (DRR) asset or as part of an aggregation of Distributed Energy Resources (DER). Creating a new market participation model that bridges the difference between DA/RT participation and Emergency Only participation could go a long way to incentivizing resources to be more available without creating increasing levels of performance requirements that could drive some resources to not participate at all. There should remain a place in the MISO construct that allows for emergency only response.

APGI appreciates the opportunity to provide feedback on this issue.

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

Sherry Rhodes

Alcoa-APGI

(812) 853-1033

Sherry.Rhodes@alcoa.com

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

The MISO solar capacity credit should decrease over time as more solar on the distribution system is added.  Distributed solar looks like negative load to the transmission system.  As more distributed solar is added the MISO net load peak gets pushed back to later in the day when solar output is less.

See MISO Long Term Regional Transmission Planning Solar Load Shift Slide 12-5-2018 p.7.

See MISO MTEP19 Futures PAC Meeting 6-13-2019, p. 25.

WEC Energy Group supports a capacity accreditation construct that is the same for all resource types.  Accreditation of resources should result in capacity that provides the same value during the same times of need.  The probabilistic ELCC accreditation of intermittent resources and performance-based Schedule 53 accreditation of nonintermittent resources are distinctly different approaches to resource accreditation.  One is based on a probabilistic simulation of the ability to serve load for a fixed LOLE (along with the inherent assumptions about the remaining portfolio) while the other is based on actual resource performance during times of need (Tier 2 hours) and performance during other times (Tier 1 hours).  During the upcoming workshop, we would like to explore how these distinct approaches result in reliability-neutral capacity values that can be directly exchanged for one another.  It seems that if ELCC is needed to capture the correlated and infrequent risks (such as extreme weather) for intermittent resources, the same should be true for all resource types.  On the other hand, if Schedule 53 accurately captures the capacity value of resources during times of actual need, whether driven by extreme weather or other factors, we would like to better understand why ELCC is superior to Schedule 53 for intermittent resources.

Our comments about comparisons between ELCC and Schedule 53 are premised on a common set of underlying assumptions for both accreditation approaches.  In other words, the same 3 year historical window should apply to both.  Additionally, we believe that average, rather than marginal, ELCC is a better measure of the capacity value of a resource type, but only if applied to all resource types.

We believe that a Schedule 53 approach could also work with LMRs, but only if the Demand Side Resource Interface (DSRI) tool is structured to accurately record actual operations.  For example, a 100 MW air conditioning demand response program will only have 100 MW available on the hottest summer day.  On other summer days, that air conditioning load might only be 70 MW (because 30 MW of load simply isn't there).  The DSRI must allow for this information gathering so that the LMR is given 100% availability credit (during Tier 1 and Tier 2 hours) even though the air conditioning load is 70 MW.  The same applies to industrial load that is registered as Demand Response.  On any given day, that industrial customer's load may be lower, meaning the amount of DR is also lower but available at 100% nonetheless.  In contrast, if the load associated with DR is consuming but not available for curtailment (an "outage" of the DR "resource"), then the DSRI will reflect that information and Schedule 53 will properly penalize that DR.

Voltus would like to reiterate the comments we previously submitted on August 3 regarding LMR capacity accreditation. Those comments are available here: https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/rasc-lmr-non-thermal-accreditation-feedback-rasc-2019-2-2020-4-20220713/. 

Any effort to accredit LMR based on its availability during tight system conditions should be set up only on a go-forward basis and only using availability data after such a construct is adopted. Historical data are not accurate enough to inform estimates of expected future availability. Historical data were also provided to MISO by market participants following a different set of rules and financial incentives than are now being proposed. For example, LMR previously only required 3 months a year of availability, so many resources show 9 months of 0 availability data. Additionally, the slide from the most recent RASC meeting that outlines how FSL-type resources should show their availability in the DSRI is the first guidance MISO has provided about how FSL resources should manage their availability using the "self schedule" option. Historical data for FSL resources in the DSRI will exclude these "self scheduled" MW, and therefore chronically underestimate availability.

Thank you for the opportunity to comment and for considering the aggregator community in this stakeholder process.

Emily Orvis, Senior Director of Energy Markets, Voltus, Inc.