In the January 28, 2022 meeting of the Reliability Subcommittee (RSC), stakeholders were invited to review and submit feedback on the Proposed Tariff Changes for Generation Limitations provided by the Transmission Provider (TP) or Transmission Operator (TOP).
Please provide feedback by February 18, 2022.
At the RSC on 1/28/2022, MISO described the proposed tariff changes for generation limits provided by the Transmission Provider or Transmission Operator, as incorporating existing procedures into the tariff. WPPI notes that the Generation Stability Limits procedure (SO-P-NOP-00-497 Rev: 0) has been in effect for just over a year (issued and effective 1/15/2021). WPPI reviewed MISO’s proposed tariff changes and they appear consistent with Option 1 of the procedure whereby the TOP communicates limitations to the Generator Operator and the GOP does not offer above those limitations in Day-Ahead and Real-Time. Subsequently attached to this feedback are WPPI’s comments on the proposed tariff changes, which we provided directly in the “Redline” documents posted with the meeting materials.
In addition, WPPI would ask that the RASC consider the implications of the Generation Stability Limits procedure, in particular Option 1, for capacity accreditation under MISO’s recently proposed changes to capacity accreditation (ER22-495).
Ameren shares stakeholder concerns that the proposed tariff changes, intended to align the tariff with the generation stability limits procedure, could have the unintended consequence of negatively impacting resource capacity accreditation. We request that MISO consider this potential impact in its tariff revisions as necessary to ensure the full capability of generation resources is accurately reflected in capacity accreditation.
Ameren appreciates the opportunity to comment on this issue.
MEMORANDUM
TO: MISO RELIABILITY SUBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: GENERATION STABLITITY LIMITS PROCEDURE – PROPOSED TARIFF ALIGNMENT
DATE: FEBRUARY 18, 2022
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the January 28, 2022, Reliability Subcommittee (RSC) meeting concerning aligning portions of the MISO Tariff with the current Generation Stability Limits procedure. In addition to the comments below regarding this alignment, the EOCs would like to raise a related concern with MISO’s recent Seasonal Resource Adequacy Construct filing with FERC. Given MISO’s proposed Resource Adequacy changes, the current Generation Stability Limits procedure will negatively impact a resources accreditation, when it should not. As such, we think that further discussion and changes are needed if the as filed version of the Resource Adequacy Construct is approved by FERC.
Given the current procedure, in which 1) The Transmission Operator (TOP) communicates the resource’s limitation to the Generator Operator (GOP) then 2) The GOP updates the Control Room Operations Window (CROW) with the TOP requested resource limits and the appropriate cause code and 3) The related resource’s offer is then limited accordingly, the proposed Tariff changes do seem to align with and protect this process against Physical Withholding or Must Offer issues.
The proposed Day Ahead Margin Assurance Payment (DAMAP) Tariff language, in which the resource will lose DAMAP eligibility if the Day Ahead offer does not reflect the TOP limitation, is of concern since the current process is burdensome to the GOP and there is no guarantee that the TOP would provide the limits in a timely manner.
Rather than make any changes related to the current process, the EOCs ask that MISO and related parties work together to revamp this process. One possible solution would be to have MISO and TOPs communicate and incorporate these transmission system stability limits into the various MISO Day Ahead and Real Time commitment, pricing, and other market optimization engines. Then, a GOP would just offer in the know operating parameters of its resource, with improved MISO Market systems limiting and optimizing resources as appropriate via pricing and dispatch signals, driving greater efficiencies.
The EOCs appreciate the opportunity to comment.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
WEC Energy Group supports the proposed tariff changes to align the tariff with the Generation Stability Limits Procedure. However, additional tariff changes are required to ensure that the capacity accreditation of resources whose offers are limited by the stability procedure are not negatively impacted. Under proposed Schedule 53 of the tariff, resource availability for both Tier 1 and Tier 2 capacity accreditation is determined from the Hourly Emergency Maximum Limit. If the Hourly Emergency Maximum Limit is reduced to reflect a stability limitation per the procedure, the availability of the resource should reflect the full capability of the resource.