RASC: OMS MISO Survey Seasonal Adaptation Questions (20220713)

Xcel Energy appreciates the opportunity to provide comments on the seasonal construct changes for the OMS-MISO Survey.

1. After considering seasonal balance sheets, what is desired for how to represent them?  By season?  All seasons?  Other?

   Xcel Energy recommends that both the seasonal and all season options should be available to accommodate all preferences. 

2. Post-processing changes: GIA/queue inclusion rate and default certainty settings? 

   We provide the following recommendations for post processing changes:

• Separate line item (category) for new resources reusing an existing interconnection be a separate category.  The retired resource would to be removed as a High/Low Certainty Resource the year of accredited capacity retirement.
• Seemingly resource at existing interconnections have a higher likelihood of success, differentiating from projects in the GIA queue.
• This recording allows “gaps” in capacity credit, between the original and replacement, to be apparent.
• Differentiate DPP Phase 1 from IRP “Planned” Resource.  DPP Phase 1 has a site/proposed equipment/commenced permitting.  IRP “Planned” Resources are plans/intentions/modeling output without commitments.
• Is High/Low sufficient?  Would a different label have better identified the tenuous nature of the coal units that retired early? 

3. Any other ideas regarding the conversion of the OMS-MISO Survey to a seasonal format?

   We propose the following ideas:

• Add formulas to each line on the Balance Sheet.
• Audit CP nodes reported in the OMS MISO Survey against the CP Nodes active on the system.  This will catch IPP resources that are bidding into the market, not through an MP.
• Follow-up with CP Nodes that are not reported by MP’s.
• This audit could also be used for the GIA queue as there are many resources that are speculative, not contracted for offtake.

1. After considering seasonal balance sheets, what is desired for how to represent them?  By season?  All seasons?  Other? 

Data provided by season would be greatly appreciated and useful insight.

2. Post-processing changes: GIA/queue inclusion rate and default certainty settings? 

The default selection for the “certainty” of a resource could most likely resemble a “did not respond,” with options for both high and low certainty to be selected. If possible, an automated email to the responsive party for the “did not respond” resources could then be sent asking for follow-up, if any.

Otter Tail Power would find both pure data provided in the survey, by season, and an “in-line rate” that MISO develops from historical additions and best estimates appropriate to provide to stakeholders.

      3. Any other ideas regarding the conversion of the OMS-MISO Survey to a seasonal format? 

Ease of use import and export abilities will be critical to successful participation in the adaptation to a seasonal OMS survey format.

ITC Holdings Corp. (“ITC”) appreciates the opportunity to provide feedback on the conversion of the OMS-MISO Capacity Survey (“Survey”) from an annual to a seasonal basis.

ITC believes the actions OMS, MISO and stakeholders are taking to convert the Survey to a seasonal basis will ultimately improve the reliability of the BES by improving States’ abilities to coordinate prudent, cost-effective capacity retirement and expansion plans.

The OMS Resources Work Group (OMS RWG) appreciates the opportunity to provide feedback to MISO regarding possible changes to the OMS-MISO Survey. The OMS RWG focuses its response on Question 2 of the feedback request, related to questions on post-processing changes.

Should all signed GIA be included?
The OMS RWG asks that MISO present the relevant data on when these resources achieve commercial operation relative to their initial request date. MISO states that resources with a signed GIA may connect 2-3 years after the initial request date, but information is needed on the distribution of in-service date vs. initial request before any changes to how they are treated in the OMS-MISO Survey are made. MISO should also address whether the recent history of in-service date lag time is likely to change, as delays in the last 2+ years were likely influenced by the transient effects of fiscal incentives (wind), threats of import tariffs (solar) and delivery chain problems (COVID); which are unlikely to continue in the future. Ultimately, any changes/additions to the OMS-MISO Survey should be done in such a way as to avoid disrupting the continuity of information relative to past surveys

Add queue only at a rate in-line with past additions?
While a note indicating the historical trend of interconnection requests may be warranted, the OMS RWG opposes including separate tables with an annual UCAP cap on potential new capacity additions for the following reasons:

• The current methodology already discounts capacity going through the interconnection queue by weighting the capacity based on which DPP Study Phase the generation project is currently in. These weights are based on the historical likelihood of completion.
• MISO has made recent interconnection queue reforms that should improve the process, resulting in increased (and more timely) additions of capacity.
• Given the rapid transition of the resource mix in MISO and an interconnection queue that gets larger every year, including a chart for potential new capacity in future years based off the historical rate of additions is misleading.

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

WEC Energy Group recommends that MISO, OMS and stakeholders carefully consider significant changes to the OMS-MISO RA survey.  Significant changes between two consecutive surveys often results in confusion and misinterpretation of the survey results - careful consideration of any major change is important.

The survey should align with the RA construct currently in effect.  Until FERC approves the seasonal RA construct and SAC methodology (along with an effective date), the survey should not get ahead of the construct currently in effect.  While we are not opposed to considering a seasonal approach for the survey and preparing for a future seasonal construct, we note that many LSEs (and their respective RERRAs) still perform resource planning and expansion based on the traditional summer peak perspective.  It will take time for LSEs to transition to a seasonal PRA, seasonal resource planning, and a seasonal OMS-MISO survey.  The survey should carefully align with the RA construct in effect, implementation of any new construct and the resource planning perspective of the LSEs and their RERRAs.

WEC Energy Group is also interested in maintaining a UCAP approach to the survey until much more experience (and improvements) are made to the SAC proposal.  The survey provides a multi-year forward resource planning perspective whereas the PRA is focused on prompt-year (near-term) operational resource adequacy.  Depending on the evolution of resource planning and expansion within the MISO footprint, it may make sense to maintain a differentiation between resource adequacy in the prompt-year (PRA) and in the planning timeframe (OMS-MISO survey).

Our only comment on potential changes to the inclusion of resources within the Interconnection Queue is the need to consider that several Generation Owners are pursuing new resources through the Surplus Interconnection Service and the Retire/Replace Interconnection processes.  Since these processes are not within the DPP queue, the survey should account for these types of interconnection requests.