In the April 28, 2022, meeting of the Reliability Subcommittee (RSC), stakeholders were invited to review and submit feedback on Weekly Fuel and Consumables Data Request.
Please provide feedback by May 13, 2022.
Xcel Energy appreciates the opportunity to provide feedback regarding the Weekly Fuel & Consumables Data Request.
In general, we believe that the preferred method is for the MPs to manage their own fuel and consumables supply issues with updates to reference levels and adjustments to their energy offers and offer parameters. Therefore, MISO and the IMM should be educating MPs on the steps needed to manage their supply issues and promoting the IMM's established energy limitation process to accomplish this instead of requiring a weekly survey of all coal and fuel oil units.
MISO stated during the 4/22/22 RSC meeting that the information from this survey is used by Operators for situational awareness, to better understand why a unit has an elevated offer or restricted offer parameters. So why does MISO need this information for the coal and fuel oil units that do not have supply issues/elevated offers? We urge MISO to balance the need for this information with the additional burden on the MPs. It is a waste of MP's time to provide the responses to these questions every week of the year when there are no supply issues. It is also a waste of MISO's time to review the data for units that have no supply issues. It seems that MISO could leverage the IMM Consultations and their override process (or economic withholding calculations) to identify the units with elevated offers and require only those units to submit the survey data. At the very least, if a unit could operate 24 hours a day for the next 7 days at EcoMax, then the unit is available through the Multi-Day FRAC process and no further information is warranted. Please add some cross references or checkpoints within the survey process so that only the information that is truly needed by MISO is required.
In this same line of thinking, we do support MISO removing the requirement for dual fuel units to submit their information. A gas unit with fuel oil backup is more reliable than a gas only unit so these units should not be included as they are very unlikely to have both gas and fuel oil supply issues at the same time.
We do appreciate MISO's plan to develop an API to enable MPs to upload their survey responses instead of using the Portal. That will improve the efficiency of the process over last year but it could be improved even more by educating MPs on the market processes available to manage their supply issues and requiring survey data submissions only for the units that are experiencing supply issues.
Shell Energy North America (US), L.P. appreciates the opportunity to comment on the Weekly Fuel & Consumables Data Request. Consistent with MISO’s April 28th RSC presentation on areas for improvement, Shell Energy agrees with MISO and suggests aggregating survey responses to protect confidential information and make the data available to the public. A similar request was made to PJM last October, and they began to publicly post aggregated data on December 2, 2021 without any issues. Similarly, ISO-NE also posts aggregated fuel inventory data. Transparency is important in this regard given current market conditions, as it lets the market react, adjust to conditions, and mitigate the need for out of market action.
WPPI responses are as follows to the questions posed by MISO re the Weekly Fuel and Consumables Data Request, which was discussed at the RSC, 4/28/2022:
(1) Please provide interface improvement suggestions/requests.
(a) Include alongside each question, instructions on how to respond if the question is not applicable to a unit. When such information is in a location separate from the question, it can easily be forgotten. Examples of such instructions:
(b) In the case of a jointly owned unit, where survey responses reflect ownership share (WPPI has one such unit), suggest facilitating a single response vs. each owner separately responding to the survey.
(1) Please provide suggestions regarding the data being gathered and public dissemination.
(a) All the draft questions being considered (Item 08 Weekly Fuel and Consumables Data Request, s. 8) seem reasonable and clear. We don’t have any improvements to suggest.
(b) WPPI goes to some effort to provide additional detail on our answer to a question when a text box is provided. Does MISO find this additional detail useful? Periodically (at least annually), MISO could discuss at the RSC the types of additional detail that MISO finds useful. In such a discussion, MISO could provide examples taken directly from the survey responses (with all identifying information masked) that MISO found useful. In addition, understanding how MISO uses the additional detail may allow us to better tailor our responses to meet MISO’s needs.
(c) To facilitate general awareness, WPPI would find it useful to receive a periodic email that provides a high-level summary of how fuel supply issues are impacting MISO units and operations/reliability.
MEMORANDUM
TO: MISO RELIABILITY SUBCOMMITTEE
FROM: THE ENTERGY OPERATING COMPANIES
SUBJECT: WEEKLY FUEL & CONSUMABLES DATA REQUEST
DATE: MAY 13, 2022
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to the request made during the April 28, 2022, Reliability Subcommittee (RSC) meeting concerning MISO’s proposed transitioning of the weekly fuels and consumables data request to a year-round survey.
The EOCs support MISO’s continued efforts to ensure reliability and maintain situational awareness regarding fuel supply issues. We suggest that instead of a static weekly requirement, that MISO and stakeholders work together to establish a sliding scale threshold for the reporting requirement timelines. For example, if a generator has less than a 30-day supply of inventory, then they may need to increase the frequency of their reporting. Whereas those generators with significantly more inventory may need to only report out on a monthly or quarterly basis.
Over time, MISO could use the data to develop metrics for tracking inventory health. Once adequate levels are achieved, the reporting cadence could be extended to a quarterly or ad hoc basis as a barometer check of inventory conditions. Then, if conditions warrant, the frequency could be increased again.
As discussed at the RSC, the EOCs would agree that the survey interface could be improved by having fields prepopulated with the last response provided as well as provisioning an API. In addition, I would be helpful to have the option of uploading the data via an Excel spreadsheet.
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.
Last season, WEC Energy Group submitted fuel and consumables data for 25 units. As mentioned during the RSC meeting, an API would provide those market participants with a larger number of reporting units with a more efficient and accurate process. The API’s specifications should be communicated with ample lead time so that processes and protocols can be established and tested.
In addition, MISO should provide better guidance on the following: point in time and consumables. In the past, we gathered data from across our fleet once per week and submitted that data each Wednesday. Is this approach adequate for MISO’s needs? Would MISO prefer to have the data earlier or later in the week for planning purposes? What assumptions should be made with respect to the reporting of consumables? We assumed the following reporting criteria: the one consumable that would limit unit operation in the shortest time period. For public dissemination, it might be more useful to specify which consumable is most limiting – lime, etc. Also, more guidance on reporting of joint-owned units is appreciated and would provide more accurate data. The data request will likely yield better results with the primary operator reporting for all joint owners to eliminate differences in fuel & consumables information between joint owners.