The draft LOLE study report has been posted to the Resource Adequacy page of the MISO website. Feedback is requested by October 31 and will be considered for the final version of the report, which will be posted on November 1.
WPPI provides comments and suggested edits in red-line form to be sent to MISO immediately after submission of this request.
We note that, in the process of saving our changes, spurious changes to section numbering were introduced. We did not intend these changes, which MISO should ignore.
First, it is difficult to understand how the deadline for this feedback can be included in any meaningful way being due 1 day before the release of the LOLE final report. Hopefully these concerns, which have been raised in LOLE presentations to date can be included in more detail.
The LOLE report is lacking detail on how the PRMR is calculated. The seasonal approach is even more challenging to follow and understand because of the complexity of having an annual objective of 1 day in 10 of resources being unavailable, and how this is distributed to all four seasons. Clearly, the Summer season has the higher number of LOLE tight margin hours, with some hours running into the fall and spring seasons for warmer weather that occurs in these seasons. the number of hours in the winter is much lower, and the seasonal allocation of the objective has been set to 0.01hours/year (.1 day in 10 years). So if this is the observed risks for the winter season, being the lowest value to reflect some risk, but a low risk - why is the PRMR ending up at a value that is only 3,000 MW lower than the summer, where the peak demand is 20,000 MW lower than winter? I am not following why the assigned lower risk for winter ends up "finding" the need for PRMR being so high. There needs to be a more intuitive means of showing a distribution of results that would lead an analytical based conclusion showing a PRMR that is only 3,000 MW lower than the summer season. I don't find comfort in the comparison to the annual construct in comparing the PRMR for summer compared to winter being similar. If winter has an assumed lower level of risk, then I want to see how the winter season is requiring such a high number of reserve sharing MW to cover the winter peak. The same question applies to spring season.
The next line of questions is to more clearly describe the usage of the "adjustment to UCAP" line in the results summary. We see a much higher level of negative values for the winter season - 6,500 compared to - 2,650 MW for summer. Explaining how this value is leading to a targetted value of the 1 day in 10 - winter showing more negative UCAP meaning that the analysis had more excess capacity compared to summer? I know that the mechanics of the "sign" of this value has been discussed at a high level, but the drivers that determine the value is not clearly known, and relates to the first line of question of what drives the 1 day in 10 target.
so bottom line-the additional information provided was more of the "here is the answer" approach to providing more details, without showing a step by step approach showing the analytics that drive the "adjustment to UCAP" value derivation.