RASC: Proposal to Improve Access to Available Maximum Emergency (AME) Resources (RSC-2021-2) (20220126)

MISO RASC Feedback

Hoosier Energy Rural Electric Cooperative

February 9, 2022

Hoosier Energy Rural Electric Cooperative (“Hoosier”) thanks MISO for the opportunity to provide feedback on the proposal to improve access to Available Maximum Emergency (“AME”) resources at the January 26^th, 2022, RASC meeting.

In the presentation MISO proposes to restrict use of the “Emergency” commit status by resources designated for Resource Adequacy Requirements (“RAR”). MISO stated this aligns with existing rules regarding the use of emergency ranges and the “Not Participating” commit stats and aligns with a recent IMM recommendation. MISO’s evaluation shows that more than 20GWs of resources were designated AME in the 2020/21 Planning Year with an average lead time of greater than 8 hours which made them not available to meet a potential capacity deficiency. MISO’s proposal would result in accreditation implications of must offer obligations in Modules A and C and not allow any units designated for capacity to use the Emergency commit status if they cleared the Planning Resource Auction (“PRA”) for capacity.

Hoosier opposes MISO’s proposal for completely removing the ability to use the Emergency commit flag with all units designated for capacity. We believe the proposal is excessively punitive due to a limited number of “bad actors” who use the Emergency status for a large portion of the year. The Emergency status serves a legitimate purpose for many Generation Owners when units can be made available if MISO truly needs them. Hoosier uses the Emergency commit flag as a last resort when they have units that are still available but have emissions or fuel limitations that require MISO to be in an emergency or forecasting an emergency to get authorization to commit the unit.

A real-world example is a Combustion Turbine that is limited to annual emissions limits from its state environmental agency and running close to its maximum annual limit. The Generation Owner (“GO”) would use the Emergency commit status while investigating whether these emissions limits could be exceeded by consulting with its state agencies. In the meantime, the GO also contacts the IMM and updates its reference limits to ensure that no withholding rules are being violated. After the GO determines it can still operate within it’s required limits, it removes the Emergency flag and flags the unit for Economic commitment with an increased offer curve to reflect its limits. If the GO determined that it had reached its limits and requires MISO to be in an emergency to operate, then it remains in Emergency status until such time as MISO forecasts a capacity need.

Hoosier recommends that instead of MISO completely removing the ability to use the Emergency flag for units designated for RAR, that MISO instead give a limited number of times the Emergency flag can be used for each unit and/or a limited number of hours in which a unit can be designated as Emergency. This would prohibit habitual users of the Emergency flag from using the flag for a large portion of the hours in the year. This would retain flexibility for GOs that truly only use the Emergency flag when their units are under a significant operating restriction and make themselves needed if MISO truly needs them.

Thank you in advance for considering this feedback.

The OMS Resources Work Group (OMS RWG) appreciates the opportunity to provide feedback to MISO on this topic. This feedback does not represent a position of the OMS Board of Directors.

While the OMS RWG generally agrees with MISO’s targeted outcome of having better access to committed capacity to ensure reliable and efficient market outcomes, we are not sure MISO has proposed the optimal solution to achieve this goal. Given the quantity of resources that have utilized AME in recent Planning Years, the OMS RWG is concerned that an outright prohibition on capacity resources using the Emergency Commitment Status could have a significant impact on participation in the PRA, and we encourage MISO to consider alternative proposals to meet its objectives (such as restricting, but not prohibiting, use of Emergency Commitment Status for RAR resources or an accreditation impact for long-lead resources designated as AME).

The OMS RWG requests additional information on the AME Resources.

In order to better understand the potential Resource Adequacy ramifications of the proposed changes, the OMS RWG requests the following additional information from the 2020/2021 Planning Year:

• The number of resources that were designated as AME.
• The location of the resources that were designated as AME, at least on a subregional basis (preferably down to an LRZ basis).
• The percentage of the MW of resources that were designated AME that were also capacity resources.
• The MW amount of AME Resources within each season.
• The average length of time each resource used the AME designation

The OMS RWG believes that this is a policy issue and that additional discussions should continue within the RASC.

From MISO’s information on the 2020/2021 Planning Year, more than 20 GW of resources were designated as AME at some point during the Planning Year. Given the large quantity of resources that could be impacted by this proposal and the relatively short timeline for the proposal becoming effective, the impacts to participation within the Resource Adequacy construct going forward could be significant. The OMS RWG requests that these discussions remain within the RASC. There is precedent for this to occur as the modifications to emergency-use LMRs was discussed at the RASC over the past couple of years.

MGE and MPPA generally support WPPI's comments.

Thanks,

David Sapper

dsapper@ces-ltd.com

The Entergy Operating Companies (EOCs) appreciate the opportunity to comment on MISOs proposal to improve access to Available Maximum Emergency Resources. The EOCs believe that PRA cleared resources should be able to reasonably use an Emergency Commit Status without penalty. To the extent that some resources are utilizing an emergency commit status in an unreasonable or excessive manner, MISO should identify tariff changes to restrict this type of behavior.

WPPI appreciates the opportunity to provide feedback on MISO’s Available Maximum Emergency (AME) resources proposal presented at the January RASC meeting. WPPI agrees with MISO that the case of AME units of units with long lead times raises concerns given typical timing of MISO emergency operations. We support MISO’s proposal to develop “the ability to call on AME units in advance of an emergency as we did for LMRs in [the] 2018 RAN phase 1 filing.” To the extent that ability to commit long-lead AME resources in advance of an emergency still leaves MISO unable to make reasonable use of their capacity in emergencies, accreditation adjustment would seem appropriate. However, we disagree with MISO that outright elimination of AME status is necessary. WPPI suggests that MISO consider AME status in a manner similar to planned-outage status for accreditation purposes. Given the emergency-timing considerations MISO cites, differentiating between units based on AME notification and start time appears appropriate, similar to what MISO did for LMRs in RAN Phase 1. For example, an AME unit with notification and start time exceeding 6 hours could be considered on outage for accreditation purposes, with no impact to AME units with shorter lead times.

Finally, we understand that the distinct issue of limits on the number of deployments for capacity resources may be contributing to the issues MISO is seeing. If this is indeed the case, we recommend that MISO bring this issue to RASC alongside the AME issue, recognizing it as a distinct issue with potentially distinct solutions.

Shell Energy North America (US), L.P. appreciates the opportunity to provide feedback on Available Maximum Energy (AME). Shell Energy is interested in seeing more data surrounding how the Emergency Commit status is used today and support the requests made at the January 26, 2022, MISO RASC meeting, by other market participants. Additionally, Shell Energy would like to see the following summarized data which should still respect individual generator confidentiality. 

• Distribution or histogram of resources by average MW or total MWh by lead time in Emergency Commit status
• MW of resources in AME that were available and not available based on lead times during past MISO emergency declarations
• Provide a distribution of reasons for which resources have historically used the Emergency Commit status (i.e. environmental, fuel, temperature, outages, etc.) which would help inform when the status is being currently used and why.

Shell Energy thinks this additional data would be useful and help inform stakeholders as they collaborate with MISO on a solution. 

WEC Energy Group does not agree with MISO’s proposal to prohibit the use of the Emergency Commitment Status for resources designated to fulfill Resource Adequacy Requirements. Rather, we support consideration of mechanisms within proposed Schedule 53 to account for the use of “emergency-only” status within accreditation.

As noted during the Jan 26 RASC meeting, there are times when a generation resource is unavailable for normal commitment but is available should an emergency arise. Prohibiting the use of “emergency-only” status will require the Generation Owner (GO) to submit a planned outage when a resource is unavailable for normal commitment, rendering the resource unavailable for emergencies (at least in terms of MISO's visibility). In our opinion, this degrades reliability. A mechanism to communicate that a resource is unavailable for normal commitment but available should an emergency arise provides operational visibility and flexibility to deal with an emergency.

We do agree that a resource that is unavailable except for emergencies has less resource adequacy value than one that is available for both normal and emergency conditions. Rather than removing an operational tool such as the Commitment Status of Emergency, MISO and stakeholders should consider enhancements to MISO’s proposed availability-based accreditation within Schedule 53 to account for the use of “emergency-only”. We provide the following suggestions for further discussion and evaluation:

1. Schedule 53 already assigns a Tier 1 and Tier 2 availability of 0 MW to a resource whose Start-Up Time plus Start-Up Notification Time exceed 24 hours – this applies to all capacity resources including those with “emergency-only” offer
• No need to apply further accreditation reductions to "emergency-only" resources based on commitment lead time
2. Consider lower Tier 1 accreditation for “emergency-only” resources
3. Consider lower Tier 2 accreditation for "emergency-only” resources:
• Should Tier 2 availability be weighted based on the amount of time a resource is “emergency only” (e.g. less than 6 hours – 100%, 6 to 12 hours – x%, 12 to 24 hours – y%, etc.)?
4. Similar to the treatment of LMRs, consider a process to commit “emergency-only” resources in anticipation of an emergency

Xcel Energy appreciates the opportunity to provide feedback regarding Available Maximum Emergency (AME) Resources.  We believe that the use of an "emergency" commitment status should be applied differently for capacity and non-capacity resources.  For example, we feel it is appropriate to use the "emergency" commitment status for non-capacity resources, without additional documentation, at all times.  Therefore, we are in agreement with MISO's current proposal regarding non-capacity resources.

For capacity resources, we would propose a tiered structure such that the use of an "Emergency Commitment Status" could be used if the MP is able to provide documentation that there are environmental , fuel, labor, maintenance or other issues that would make it unreasonable to commit the unit unless an emergency event occurs.  MISO's current proposal of not allowing capacity resources to offer with an emergency commitment status would subsequently reduce the amount of generation that would be available in an emergency because the unit would have to be offered in an "Outage" status.  MISO has to provide a way for MPs to signal to the market that the unit is only available for an emergency situation, i.e. there are non-monetary (reliability) hurdles that need to crossed.   The emergency commitment status is a necessary tool to handle these situations on a short-term basis.  As an example, some environmental permits allow for permit limitations to be exceeded only if an emergency event occurs.  How would an MP signal this availability to MISO?

We urge MISO to work with stakeholders to find a more eloquent solution to enable capacity resources to use an emergency commitment status when conditions warrant.  The current proposal which allows capacity resources to offer only for economics or in outage is a brute force approach that will have unintended consequences on system reliability.

Additionally, we would like to understand how MISO Operators will call on AME resources when their lead time is greater than two hours.  Is MISO planning to incorporate this ability into the RAC processes or will it be a manual commitment?  We ask MISO to provide more details on this process at the RSC.

MidAmerican appreciates the opportunity to provide feedback on the proposal to improve access to Available Maximum Emergency (AME) resources (Issue RSC-2021-2).

First and foremost, MISO needs to clearly identify the concern. Is the concern that capacity units are using the commit status of “Emergency”, that it is being used frequently or that some units are using it exclusively? MidAmerican is concerned that the rules for when a unit can use the commit status of “Emergency” needs to be clearly spelled out in the appropriate BPM.

The proposal where a capacity resource uses the commit status of “Emergency” and has a lead time > 2 hours it does not get credit for being available during that RA-hour in our new seasonal availability-based RA proposal being discussed at the RASC is both unjust and unreasonable. The entire reason for having resource adequacy is having resource available to supply firm load when needed. This is no difference than other resources (such as LMRs) that get credit for capacity even though they are only utilized during emergency conditions or units that have a lead time of 24 hours that are not in emergency. For example, a unit could have a state mandated fire suppression test that it needs to perform but if a system emergency were to occur, the inspector could be contacted to relocate to a safe location and the unit could be committed, but during normal operations it would be our preference to perform the inspection. It seems like MISO would rather have this unit available to them in an emergency than have the unit in an outage.

Other conditions that might warrant an “Emergency” commit status if a unit can currently run, but by running the unit it could do a small amount of damage because the unit is waiting on parts to fix an issue. MidAmerican is willing to run a unit, knowing that it will incur damage if it is needed to keep the lights on, but not willing to run it for pure economics. If this isn’t an acceptable use of the “Emergency” commit status, then MISO needs to make this clear, but again, it seems like MISO would rather have access to a unit in an emergency instead of not having access to it at all.

Southern Minnesota Municipal Power Agency (SMP) appreciates the opportunity to comment on the topic of Available Maximum Emergency (AME) resources.  SMP has some of the same concerns as raised by others at the January 26, 2022 RASC meeting.  This effort must not be taken lightly since it has the potential to harm reliability rather than help if not done correctly.

Concern Based On Misconceptions:

SMP is concerned that there may be some misconceptions regarding a generator’s use of the Emergency commit status.  As a result, this proposed rule change may in fact be attempting to remedy a problem that does not exist.  The idea that generators are using the Emergency commit status to eliminate the need for an outage may be true, however they are doing it to help improve MISO system reliability, not weaken it. This will be explained in more detail below.

Methods of Offering Emergency:

Currently there are two methods (that SMP is aware of) for a resource to limit their market operations to emergency conditions.  One would be to enter a commit status of “Emergency”.  The second would be to offer a commit status of “Economic” but set the Emergency Max Limit to a value higher than the Economic Max value.  These two issues will be discussed separately below.

Emergency Commitment Status:

There are numerous situations where a generator could wish to submit a Commit Status of Emergency rather than taking an outage. This not only helps the generator’s capacity accreditation, but also helps increase system reliability.  On the day of this RASC meeting SMP actually had one of its plants on Emergency commit status because we were giving tours to a local community group.  If we were to take a planned outage for this instead, the plant would not be available to MISO if an emergency were to occur. On the other hand, since we offered it as Emergency commit status, if a MISO emergency were to develop, the plant could stop the tours immediately and have the generators on-line in 10 minutes.

This is only one of literally hundreds of examples where preventing a generator from submitting a commit status of Emergency would actually harm reliability. Occasionally when we have safety meetings or other Operator training activities, SMP may place the plant on Emergency status so the Operators can concentrate on the subject at hand. However, if an emergency were declared by MISO, the meeting can be terminated immediately, and the plant could be on-line within minutes. 

Staffing limitations are another reason for an Emergency commit status. Many intermediate and peaking plants are not staffed 24/7.  There may be times when plant staffing is limited, requiring the plant to submit an Emergency commit status.  If an emergency were declared, it would allow the utility General Manager to override normal procedures or policies to staff the facility for the emergency condition.  The alternative would be to place the plant in an outage in which case it would no longer be available to MISO if an emergency were to occur.

State inspections, equipment testing, and even some equipment maintenance activities can many times be performed without limiting the generator’s ability to be on-line within its normal notification/start time.   There are numerous types of minor maintenance activities which a plant can perform and still be able to be on-line within its normal startup time requirements.   Submitting a DA commit status of Emergency allows the utility to schedule labor and other resources without worrying about a DA Economic dispatch. This allows the work to be scheduled and still be 100% available to MISO in the event of an emergency.  

There are a multitude of examples where allowing a generator to submit an Emergency commit status keeps the generation available to MISO when they need it the most.  Conversely, prohibiting a generator from using the Emergency commit status will reduce the amount of capacity available to MISO during an emergency, thereby making the MISO system less reliable.

The point should also be made that many of the uses of the Emergency commit status are due to situations that are not known months in advance, much like the “opportunity” planned outages discussed by the RASC in the past.   These situations typically occur with shorter notice. As a result, if a generator is prohibited from offering the plant as Emergency, the resulting planned outage would be on short notice making it more difficult for MISO to manage.

Emergency Max Offer Limit > Economic Max Limit

There are many reasons why a generator may offer an Emergency Maximum limit higher than its Economic Max limit.  In most cases, this practice will tend to increase system reliability by making a generator’s maximum operating capability available to MISO during emergency conditions as opposed to taking a planned out forced derate.  Many of the same issues as described above can be a reason for this practice.   However, the most common reason is due to the difference between the plants Net Maximum Capability (NMC) and its Net Dependable Capability (NDC).

 A generator’s Net Dependable Capability (NDC) is sometimes referred to as the plant’s “cruise rating” or “sweet spot”.  This is the output level where the plant can safely and reliably operators on a continual bases, 8760 hours/year.  The Net Maximum Capability (NMC) is an output level where the plant can operate for a defined period of time but can not, or should not, operate at this level continually.  In order to increase their output from NDC to NMC, the plant may need to take certain steps such as increase main steam pressure, decrease soot blowing, remove feedwater heaters from service, exceed environmental limits, call in additional staff, or reconfigure certain equipment.  In most cases, the plants must limit the amount of time that they operate in this mode due to physical or environmental constraints.

Under this scenario, many plants will set their Economic Maximum offer limit at their Net Dependable Capability (cruise rating) and set their Emergency Maximum offer limit to its Net Maximum Capability.  When MISO declares an Emergency condition, these plants can increase their output from their NDC rating to their NMC.   The amount of time it takes to reach this output level and the amount of time that a plant can operate at this level will be different for each plant.  If however plants are restricted from using their NMC as its Emergency Max limit, MISO would not have this capacity available to them if an emergency was declared.   In addition, generators typically use this offer strategy every day. As a result, this generator can have a small portion of their capacity in Emergency Max 100% of the time.   This may seem strange at first glance, however, it does serve an important purpose in helping to improve system reliability.   

There is another reason for offering Emergency Max greater than Economic Max that may be unique to smaller utilities. Many of SMP’s generator cpnodes consist of multiple, smaller, generators.  Some of these generators have modern computer controlled operating systems and some are older, manually operated generators.   In some cases, the more modern generators can be on-line in 15 minutes whereas the manually controlled generators need more notification time to call in staff and get the units started. In this case, we typically offer the automated generation as the plant’s Economic Max limit and offer the less flexible, manually operated generators as the Emergency Max limit.   If SMP were restricted from using this practice, we would have to offer the entire plant at the Economic Max limit.  In order to do this, we would need to increase the notification time to allow for the additional time needed to staff and start the manually operated units.  This would result in an increased notification time on the automated units as well thereby making them unavailable to MISO on short notice.

Also, since many of SMP’s generation cpnodes consists of multiple generators, SMP may sometimes offer some of the facility at the Economic Max limit and a portion of the facility at the Emergency Max limit. This allows SMP to perform minor maintenance activities on part of the facility without taking a planned outage, as long as the full capability of the facility is available within its normal notifications/startup time constraints.  Once again, this helps to improve reliability be keeping these units available to the system in the event of an emergency.

Unintended Consequences

It is always important to look at the possible unintended consequence of any practice or policy change.   The most noticeable consequence of restricting a generator from utilizing the Emergency commit or max limit modes is that the generating plant will be forced to take a planned or forced outage or derate on relatively short notice instead.  This will reduce the capacity available to MISO in the event of an emergency.   

Smaller generators, such as SMP’s, may decide to change the registration of their facility to LMR/BTMG in which case the energy from these facilities would no longer be available to the energy market and MISO’s ability to deploy this capacity would be even more constrained under LMR rules.

In addition, if generators are not allowed to offer their Net Maximum Capability (NMC) under their Emergency Max limit or are restricted from including it as capacity in their FRAP, there would no longer be any incentive to run their GVTC test at their NMC level.  Pushing a generator beyond its comfortable operating limits can sometimes be risky. Some plants may decide that it is not worth taking that risk if there is no benefit.  This will also reduce the amount a generation available to MISO during an emergency.

Other generators may choose to raise their Economic Max limit to their Emergency Max limit rather than reducing their Emergency Max down to its Economic Max.  In other words, offer their full Net Maximum Capability (NMC) as Economic rather that Emergency.  In order to do so, they would have to place additional restrictions on other operating parameters such as increasing their notification time to account for the time needed to operate at their NMC level.  These increased restrictions will put additional impairments on MISO and reduce overall reliability. 

Comments on January 26, 2022 RASC Presentation

On page 3 of the presentation, MISO states that “Most AME resources are not available in the timeframe they are needed to address capacity insufficiency”.   SMP does not agree with this statement.  None of the AME type situations discussed above in this document would prevent a resource from deploying their emergency capacity any longer than their normal notification/startup time.  As long as the resource can deploy within their normal time limits, MISO is indifferent as to whether the offer is Economic or Emergency as it pertains to system reliability.

All generators will experience times when they can not perform to their full capability.  Any “insufficient” performance that MISO may perceive for AME resource is most likely no worse than any other non-AME resource.  In fact, we would venture to guess that most of the Emergency commit status submittals are done so for very good reasons and are done so to help improve MISO system reliability.  We would encourage MISO to conduct a more detailed study on the issue before drawing any conclusions or making any changes.

Also, it is important to note that a generator will not automatically go to its Emergency Max limit when an emergency is declared, therefore MISO should not use this as a measure of AME performance. MISO emergency procedure state that a resource should deploy its emergency capacity only when requested by MISO otherwise the generator may be deploying capacity that MISO was holding in reserve.    

Finally, on page 4 of the presentation, MISO states that the proposed new process should “Allow Operators to call on any remaining non-capacity AME resources in anticipation of an Emergency Declaration….”.  This may not be a valid assumption.  If generators are prohibited from obtaining capacity credit for their Emergency generation capability, there will most like be no non-capacity AME available for MISO to call upon.  Since there would no longer be any capacity benefit, generators would most likely retire these assets or change their operating strategies as noted above under “Unintended Consequences”, resulting very little non-capacity AME resources available to MISO.  

Summary

In conclusion, SMP believes that,

1)      the misconceptions about AME resources’ use and performance are not valid,

2)      the use of various AME operating modes help to improve system reliability, and

3)      restricting a resource’s use of AME operating modes will reduce overall system reliability, and

4)      SMP recommends that the issue be studied in more detail to determine if a problem actually exists, and if so, identify the root causes, before making any rule changes.

Duke Energy appreciates the opportunity to comment on this important topic.

Duke believes that the issues here could be solved through accreditation instead of administrative restrictions.    For example, for accreditation, a commit status of emergency would be treated as a forced outage (no accreditation), unless the system is in an emergency (which by definition would be an RA hour). In the emergency then, the emergency availability receives the 80% weighting, whereas for the other hours it receives no accreditation, but only at Tier 1 20% weighting. This mitigates the overall accreditation impact, while providing the proper signal to the generator to actually be available and run during the emergency.

Thanks again and looking forward to discuss more.

Alliant Energy has significant concerns on the AME topic. Mainly:

• From the RASC discussion and material it appears that MISO needs to focus on “bad actors” that are most egregiously taking advantage of the Emergency commit status.
• Stakeholders have appropriately pointed out that occasional Emergency commit is a necessary part of operating and maintaining the generating fleet, especially for dispatchable coal and natural gas fired units. These are the units MISO is depending on to maintain reliability, so it makes no sense to unnecessarily penalize these units.
• MISO needs to include a balance for flexibility in any proposed change. In other words, allow Emergency commit status provided certain conditions.
• The proposed tariff addition - “The Emergency Commitment Status will not be available to any Resource that has all or a portion of its capacity designated as a Capacity Resource.” - certainly goes too far by ignoring the needs of realistic operations.
• Per the RASC discussion, it was confusing whether the IMM actually requests an AME change, which clouds the appropriateness of the proposal. MISO needs to sit down with the MISO so that MPs have clarity on the fundamental issues.

Ameren Missouri does not support MISO's proposal to prohibit RAR committed resources from using a commitment status of Emergency.  This proposal is entirely inconsistent with the accreditation rules for Demand Response LMR and EDR resources that have limited availability but can receive up to 100% capacity accreditation.  The proposal is also inconsistent with the realities of how MISO Market Participants must manage their unit offers to comply with State laws that limit generator emissions.  This proposal would restrict units that are available, but committed in Emergency status to comply with state emissions regulations, thus potentially creating inaccurate capacity constraints by discrediting resources that are available if needed.  MISO should consider the impacts of state legislation on generation offers and ensure there is alignment in commitment parameters before moving forward with this initiative.