RRA Feedback on Multiple Topics (20221110)

WPPI offers the following feedback on the Regional Resource Assessment Workshop, 11/10/22, topic 3 Insight into what information from the RRA is most useful:

(a.)  The 2031 and 2041 snapshots of the capacity contribution of solar, wind, solar plus storage, and stand-alone storage

(b.)  How the current Short-term Reserve Product may evolve to address flexibility needs

Slide 5 shows no wind or solar in LRZ 4.  I find this hard to believe considering the Illinois CEJA law.

Slide 15 states that challenging events are multi-day low-wind events, solar eclipse, extreme weather.  Cloudy days can also be added, especially if the cloudiness is widespread.

Slide 16 state that the Duck curve pattern emerges in winter, early spring and late fall driven by the increase in solar generation.  But Slides 28 and 34 state that solar capacity contribution increases in fall/winter.  How can this be?  Distributed solar shifts the peak to later in the day, decreasing solar’s capacity value as more capacity is added to the system.  The December peak occurs after 5 p.m. when it is dark and therefore there is no solar at the time of peak.

Has MISO considered the effects of snow-covered solar panels during the winter?  See us january snow cover mp - Google Search

Slide 28 states that drivers of risk in the 10-year and 20-year out portfolios include low solar and wind output.   Has MISO considered the effects of a wind drought similar to the one which occurred on January 28-30, 2020 when wind output dropped to less than 1% for 39 consecutive hours across the entire MISO footprint?  MISO needs to run a wind drought case for the 2031 and 2041 futures.  These cases should also take into account reduced solar output in the winter due to shorter days, poor sun angles, and snow-covered solar panels.  When electrification is also considered, there is a real potential for capacity and energy shortages.

Slide 28 also states that wind capacity contribution remains stable throughout the planning horizon.  Other MISO presentations such as those on average and marginal ELCC show that wind capacity reduces over time as more wind is added. MISO should compare these two presentations and merge the considerations for a unified message. 

2022 RRA Comments from the Environmental Sector

The Environmental Sector appreciates the opportunity to provide written feedback on the Draft 2022 Regional Resource Assessment (RRA). Overall, we believe that the RRA is a welcome process that provides an alternative perspective from which to view much of MISO’s planning and operating processes in a more holistic and synergistic manner. We believe the RRA will be a relevant resource for MISO, states, utilities, and other stakeholders across all of MISO’s processes to help understand the impact of the members’ current plans and any gaps that may exist in the future.

As MISO has noted, “Reliably achieving the decarbonization targets set by many MISO members and states will require an accurate and collective view of how resource plans are evolving, and a shared understanding of the ways in which operational risks and needs will emerge and shift over time.”^[1]

We congratulate MISO’s RRA team for their work so far and support updating this report on an annual basis. We greatly appreciate the addition of emerging technologies and sensitivities. It’s a known unknown, and we give kudos to MISO for examining this. In the future, it appears that MISO intends to keep the RRA as up to date as possible by incorporating the impacts of the IRA, CEJA, and any other newly passed state or federal laws, and we strongly support such updates. Below we request changes, clarifications, or other additions that we hope will improve the RRA in the future.

1. Please provide clarification of the differences between the RRA methodology and analysis and the OMS Survey in the Report, the Technical Appendix, or another publicly posted document.  Also, we urge MISO and OMS to work together to avoid duplicating work, and to bring these efforts closer together to make them as helpful as possible to all stakeholders.  The RRA brings additional analysis that is valuable to provide even more information about the expected future resource mix and the impacts of those changes.
   
   
2. In the Executive Summary of the RRA Report, there appear to be a few inconsistencies regarding the estimated accredited capacity available later this decade. Figure 1 seems to suggest a noticeable capacity shortage as soon as 2026, the text indicates that there is the potential for a small shortfall in 2027, and then Figure 2 indicates no significant shortage until after 2028.  Please clarify these differences and include that in the report.
   
   
3. The RRA indicates that the shift towards cleaner resources is happening faster than the MISO Futures recognize.  RRA suggests that MISO’s member utilities are on track to reach decarbonization levels aligned with Future 3 by 2041.  Please explain the differences between the RRA expected future resource mix, and Future 2A results, which are supposed to represent member resource plans and the impacts of the federal IRA and CEJA.  The RRA report highlights that “Wind and solar generation are projected to serve 60% of MISO’s annual load by 2041, which would reduce emissions by nearly 80% relative to 2005 levels but also sharply increase the complexity of reliably operating and planning the system.”^[2]  Do the results of the RRA indicate that Future 3A should be adjusted to ensure that it represents a more aggressive bookend than the existing member plans and state and federal laws?
   
   
4. RRA results show that the need for up-ramp is increasing 3x by 2031 and 4x by 2041.  The indication of this need suggests that MISO’s recent proposal to eliminate the eligibility for DIRs to provide ramping is shortsighted.  We recommend that MISO address the fact that the ramp product does not consider deliverability in a more holistic and non-discriminatory way, and we will be submitting comments on this separate issue at the MSC in early January.
   
   
5. The RRA analysis only assumes Future 1 load levels.  In order to provide sufficient information for utilities to plan for needed resources in the out years, MISO should also model either Future 2A or Future 3A load levels, which include the possibility of significantly more load driven by increased electrification and electric vehicles. We request that such modeling will be reflected in a 2023 RRA.
   
   
6. On page 24 of the draft RRA Report, MISO notes that “Many companies have anchored carbon reduction milestones to the year 2030, and MISO did not make any phasing assumptions to smooth the goal over multiple years. For example, if a company reported its annual emissions goal at its current level for the next eight years and indicated a steep decrease in 2030, MISO used these annual assumptions directly. This resulted in a large, single-year build-out of 28 GW of new generation installed capacity to meet the sudden emissions constraint between 2029 and 2031 (Figure 17).”  We recommend that MISO assume a more gradual build out of resources to meet the specific year goals of its member utilities, so that for example, meeting the 2030 goals would result in a build out of resources over the years leading up to 2030, rather than 28GW of new installed capacity in one year. It may also be helpful to think about linking at least some of that gradual buildout to the expected energizing of the LRTP Tranche 1 projects from 2028 to 2030.
   
   
7. MISO should consider using a consistent MW scale on Figures 20 and 23, on pages 29 and 32, respectively, of the RRA Report. This will aid in making the report more accessible and easier to read.
   
   
8. On page 35 of the RRA Report, MISO should consider using a table instead of or in addition to the three separate pie graphs. We believe this would make that information easier to digest, and thus make the report more accessible.
   
   
9. Across the RRA, batteries are only considered as a 4-hour resource.^[3] In the section of the RRA Report on Storage Capacity Contribution, starting on page 51, this 4-hour operating assumption led to a “finding that the four-hour storage duration may not be sufficient to entirely mitigate LOL risk.”^[4] While that is likely true when only modeling a 4-hour operating assumption, we believe it would still be worth mentioning the flexibility of operating assumptions, especially in severe or unusual weather circumstances. Even if not modeled, the Report should acknowledge the ability of stacking batteries in order to provide an 8-hour resource, and the ability of operators to use short term weather forecasts to anticipate low wind situations and thus change the operating instructions for the day, such as what occurred in California this past September. Further analysis of how batteries may be dispatched in extreme or unusual conditions is warranted in MISO’s 2023 RRA. The above is distinct from the long duration energy storage discussed in the Emerging Technologies section of the RRA Report as the above practices are available either today or in the very near term future.
   
   
10. We appreciate the acknowledgment of synergies between resources as it applies to resource adequacy. This is an important feature that hasn’t yet been fully integrated within more formal resource adequacy discussions in RASC.
    
    
11. Throughout the RRA Report, the risks of correlated outages among non-thermal resources is discussed in some detail; however, correlated outages also occur among thermal resources^[5], and we note the absence of any discussion of their occurrence in the Report. Correlated risks are seen for thermal resources in a changing climate with more frequent extreme weather events. That should also be accounted for when considering the need to rethink system planning and operation. This could be discussed in part on page 43 of the RRA Report, which is where the risk of thermal outages stemming from planned maintenance is discussed.
    
    
12. In reference to the “Future Tech Proxy Unit” that is the focus of the Emerging Technologies section of the RRA Report, MISO states, “When selected, the low-emissions and high-capacity factor unit replaces added wind and solar capacity.”^[6] While the Emerging Technologies section of the RRA Report is very welcome, we question the decision to only replace added wind and solar capacity with the “Future Tech Proxy Unit”, and not other added resources as well. Based on the expected cost profile (referencing the Capital Costs outlined in Table 2 of the Technical Appendix) and the expected operating characteristics, it seems that planned added thermal units are also likely to be swapped by any new low-emission and high-high capacity factor unit. At the very least, wind and solar should not be used as the only replaced resources; instead, all “added” resource types should be considered as possibly being replaced. While it is likely too late to make this change for 2022, MISO should take a more agnostic approach with the 2023 RRA.
    
    
13. The relative thoroughness of the Technical Appendix is greatly appreciated. We appreciate both the inputs and assumptions that were described in detail, along with limitations. The Technical Appendix will thus further aid stakeholders in placing the RRA in greater context.
    
    
14. Considering that the Future Technology section of the RRA report leans quite heavily on impacts stemming from the Inflation Reduction Act (IRA) and Infrastructure Investment and Jobs Act (IIJA), we suggest that the potential impacts of the IRA and IIJA also make an appearance in the Executive Summary. We expect that such impacts will eventually find their way into the “snapshot in time” that MISO takes at the start of each RRA iteration, but considering the substantial effects that the IRA and IIJA will have on the evolution of the grid and the resource mix, we believe they deserve some mention in the Executive Summary for this year’s Report.