In the February 28 - March 1, 2023, meeting of the Resource Adequacy Subcommittee (RASC), MISO presented updates to the accreditation reform proposal. Stakeholders are asked to provide written feedback on the following:
The window for comments is extended to March 24, 2023.
AES Indiana (AESI) appreciates the opportunity to comment on the Non-Thermal Accreditation Reform updates presented at the March 2023 Resource Adequacy Subcommittee (RASC). AESI does have concerns with the Direct Loss of Load (LOL) and RA hours approach versus the current ELCC approach to accreditation. The RA hour approach to thermal resources and the Seasonal Construct is new to Planning Year 2023-2024. Therefore, MISO taking on even more accreditation changes may be premature. There remains uncertainty on how the Direct LOL and RA hours approach will change capacity accreditation by non-thermal resource type. AESI and Stakeholders need more information from MISO. For example, in the January RASC, Slide 21 presented Wind and Solar Direct LOL accreditation by season. We’d like to request the same information be presented at the April RASC for Solar+Storage and Storage resources.
Louisiana Public Service Commission Staff Feedback
To RASC Non-Thermal Accreditation Reform Request
The Louisiana Commission Staff submits this feedback to the RASC Accreditation Reform Feedback Request due on 3/24/2023.LPSC Staff supports concerns raised by stakeholders regarding the speed which MISO is attempting to implement these accreditation reforms. LPSC Staff urges MISO to allow sufficient time for other market reforms such as SAC accreditation and Seasonal Construct to gain a firm foothold prior to implementing non-thermal capacity accreditation changes. This delay will allow experience gained from these reforms to be applied to intermittent resource accreditation. Additionally, substantial and continuous major changes to the capacity construct elevates the risk of unintended outcomes.
LPSC strongly encourages that MISO share with stakeholders a deeper view of underlying data and workpapers needed to understand MISO’s methodologies and results. For example, while LPSC staff understands the market theory behind the Direct LOL methodology, it is difficult to understand what the resource mix will look like with a Direct LOL method instituted. What is the market-based value of wind and solar resources if their resource accreditation value is minimized or reduced to zero in the case of solar? Is a market-based solution the optimal method or is the method(s) used by CAISO or non-RTO entities, or other options a better solution? Perhaps market-based solutions are not optimal in MISO where most of the load is served by vertically integrated LSEs.
Non-thermal resources have capacity value during non-risk hours. Any accreditation methodology adopted should recognize that value. Reliance on marginal values alone will fail to recognize the contributions made by the non-thermal resources to capacity needs at all hours. A shift in the high risk hours to later in the day is not an indicator that solar has no capacity value.
In summary, LPSC staff understands the speed with which the resource mix is changing and the need to ensure capable resources in sufficient quantities are needed to serve the load in all hours of the year. To ensure that these resources in sufficient quantities with the correct attributes are available is best addressed with a steady and measured evaluation to get to an optimal solution.
The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback on MISO’s proposed solar/wind accreditation reforms. MISO’s determination regarding this issue may have a significant impact on member utilities as they pursue renewable resource development that is key to achieving their and their customers’ goals; the EOCs therefore encourage MISO to give careful consideration to the feedback of its stakeholders in making that determination.
MISO’s Proposed Direct LOL-Methodology
The EOCs do not support MISO’s Direct-LOL methodology proposal. This Direct-LOL methodology will produce a very similar result to a Marginal ELCC proposal, and for this reason, the EOCs have the same concerns with MISO’s Direct-LOL methodology as we do with the Marginal ELCC methodology. Please see our previously submitted feedback to understand our concerns with Marginal ELCC. The EOCs continue to believe that an Average ELCC approach is the correct methodology to use for determining the fleetwide accreditation of wind/solar resources in the prompt year PRA.
The Direct LOL-Methodology is well suited for measuring the reliability value that the next wind/solar resource will provide to the MISO system, but it does a poor job of measuring the cumulative reliability value of the existing wind/solar fleet on MISO’s current system, which the EOCs believe is the primary purpose – and at a minimum, one important purpose -- of accreditation in MISO’s prompt year PRA. To illustrate this point, in a future high solar penetration system the Direct-LOL methodology will provide a near zero capacity credit to the entire MISO solar fleet. This result would indicate that the solar fleet is providing a near-zero reliability contribution to the MISO system. However, if we were to remove the entire solar fleet from this hypothetical MISO system, there would certainly be a decline in reliability and a large increase in loss of load events, demonstrating that the presence of the solar on the MISO system is contributing towards reliability to a much greater extent than is represented by the Direct LOL-Methodology near-zero value. For that reason, accrediting existing solar resources using the Direct LOL methodology would not be just and reasonable. An Average ELCC methodology, on the other hand, would accurately capture the reliability contribution of the entire wind/solar fleet to the MISO system while also sending a reasonable price signal to the market that the solar capacity credit of individual solar resources will continue to decline as systemwide solar penetration increases. To further support this point, the recently published ESIG report Ensuring Efficient Reliability: New Design Principles for Capacity Accreditation says the following about marginal ELCC:
“Second, the marginal approach does not ascribe any value to reliability benefits that accrued due to the shift in the timing of scarcity conditions. Instead, it only values resource availability during the remaining reliability risk periods. As a result, owners of some resources could claim that they are not being fairly compensated for their reliability contribution. For example, in a high-solar system, risk is shifted to the evening hours after the sun sets. The marginal benefits of adding more solar will be very low (or zero), but the early additions of solar provided significant reliability benefits that they are no longer getting compensated for.”
The EOCs agree with ESIG that the marginal ELCC methodology undervalues the reliability benefits provided by solar resources. A methodology that does not provide reasonable capacity credit to an entire class of resources commensurate with their contribution to system reliability cannot be just and reasonable.
Equity Concerns
Using a Marginal ELCC methodology will result in less fleetwide wind/solar capacity then using an Average ELCC methodology and would result in accreditation values that are inconsistent with MISO’s PRMR/LCR requirements determined in the annual LOLE study. To resolve this inconsistency, MISO has suggested that MISO system PRMRs could be reduced by the same value as the amount of wind/solar capacity that is lost due to using a marginal ELCC methodology. The EOCs’ primary concern with this approach is that it would socialize the capacity benefit of wind/solar across the entire MISO system rather than providing the capacity benefit solely to the generation owners that are incurring the costs of owning/operating the resources. Moreover, accounting for the capacity value of wind/solar through an adjustment to LSE PRMRs would not provide any benefit to merchant generation owners without a PRMR obligation in MISO, meaning that the capacity value of merchant owned solar/wind resources would be entirely received by LSEs and none of that value would go to the actual owners of the resource who are bearing the continuing cost of their investment therein.
System Reliability Impacts
In its comments at the RASC, MISO appears to be concerned that the Average ELCC methodology would not send a reasonable price signal or provide the proper incentives to LSEs and generation owners to supply the type of resources needed to ensure reliability in all hours. This concern is without merit. Adopting an Average ELCC methodology instead of a Marginal ELCC methodology will not result in higher future system risk because it ensures that the cumulative amount of capacity credit provided to solar/wind never exceeds the true reliability contribution of these resources. For example, once the system risk hours have moved entirely to the non-daytime periods, adding additional solar resources under an average ELCC methodology will not result in additional cumulative capacity credit provided to the solar fleet. Instead, the cumulative solar fleet capacity will plateau and remain at a constant value that accurately captures the fleet’s reliability contribution, even as more and more solar resources are added -- and as more solar resources are added, the incentive to add more solar resources will be increasingly muted for LSEs that wish to secure capacity value. In that regard, MISO and the industry at large have provided study results projecting how solar/wind capacity credit will decline over time under an average ELCC methodology, and MISO LSEs already consider and incorporate these assumptions into their long-term supply plans, which are regularly refreshed and updated.[2] As a result, LSEs are abundantly aware that supply plans must be designed to account for the expected lower capacity contribution of solar/wind resources in future years as renewable generation penetrations increase. Thus, there is no reason for MISO to believe that adopting an average ELCC methodology will result in a less reliable system as compared to adopting a marginal ELCC methodology.
Entergy Proposal
If MISO is not willing to adopt the EOCs’ preferred method of an Average ELCC methodology for accrediting wind/solar resources, the EOCs propose as a compromise that MISO adopt a blended Average ELCC and Marginal ELCC approach, where MISO would calculate the Average ELCC and the Marginal ELCC separately and then average the two methodologies together to produce a final result. The hybrid approach would seek to balance the competing interests of (1) sending a proper signal regarding what types of new capacity are needed within the market (although, as noted above, the Average ELCC method will send a similar signal as more solar is deployed) and (2) providing credit to existing resources that is commensurate with their true contribution to system reliability. Moreover, this hybrid approach would be similar to the decision that MISO made with thermal SAC accreditation to use a tier 1 hours and tier 2 hours evaluation structure. The purpose of the tier 1 hours inclusion is to reward thermal generation for being available during non-tight margin hours. Including an Average ELCC component in the solar/wind accreditation would reward solar resources for the daytime reliability value provided by solar that causes system risk hours to shift to non-daylight periods. Under this hybrid approach the EOCs believe that equal weighting should be given to the Average ELCC and Marginal ELCC components and that the resulting decline in solar/wind accreditation should be deducted from system PRMR requirements as MISO has already proposed as part of a Marginal ELCC methodology.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
[2] LSEs such as the EOCs are continually refreshing their resource plans to account for constantly changing circumstances, including changing load forecasts, changing resource capacity value assumptions, changing resource costs, and MISO’s market signals, among many other factors. For this reason, MISO should not be concerned that there will be significant “lag” in LSEs responding to market signals or MISO technical study results and certainly should not have the misimpression that the opportunity to respond to such signals only arises every few years, consistent with the IRP cycles.
ICC staff continues to discuss the value of average versus marginal accreditation approaches. As part of our discussion, a number of questions have arisen and addressing this uncertainty would help with clarifying our stance.
First, ICC staff asks MISO to expand on the capacity value of solar resources during peak times. MISO’s presentation shows that the prevalence of solar has shifted risk from traditional afternoon peaks to evening hours when solar is no longer available. But, through reducing peak load earlier in the day, solar units are still providing energy that improves reliability during high demand periods. That peak shaving has value and seems deserving of compensation. ICC staff is concerned that reliability problems would arise if solar units were not compensated for this capacity work and subsequently went offline. Would a blended average and marginal approach better capture the peak shaving benefit solar resources provide? In addition, is it possible to develop a future attribute that rewards renewable resources for providing energy during peak times?
Second, does the Direct LOL approach proposed by MISO still include unit performance during RA Hours as part of the accreditation process? If the Direct LOL calculation does still include those RA Hours, could the RA Hours selected for the Direct LOL calculation be expanded and include those previously risky afternoon hours that solar has shifted to the evening? Would expanding RA Hours in this way effectively blend marginal and average approaches? Would it meaningfully improve marginal accreditation for renewable resources?
Third, ideally marginal accreditation should send price signals that encourage more storage and hybrid resources to develop thereby maintaining reliability. Given that, what are MISO’s plans to develop accreditation for storage and hybrid resources?
Fourth, ICC staff is curious how marginal accreditation methods will impact the PRMR of states with public policy goals. ICC staff is concerned that marginal accreditation will mean Illinois struggles to meet its PRMR goals, as state policy moves away from thermal and towards encouraging the development of renewable resources. Does MISO have any insight into how states with large solar or wind investments will meet their PRMR goals as renewable accreditation declines under marginal accreditation approaches?
Finally, how will the accreditation changes impact the MISO queue? That is, if we see resource shifts in response to accreditation changes, such as many of the solar resources in the queue adding storage and becoming hybrid resources, how will those changes be accounted for? Prioritized? Moved to the end of the queue for restudy?
Mississippi Public Service Commission Feedback Regarding
Accreditation Reform (20230228-0301)
MISO Requested Feedback Statement:
In the February 28 - March 1, 2023, meeting of the Resource Adequacy Subcommittee (RASC), MISO presented updates to the accreditation reform proposal. Stakeholders are asked to provide written feedback on the following:
- MISO's proposed Direct Evaluation of LOL hours
- LOL accreditation methodology
- Planning Reserve Margin calculation
MPSC Feedback:
The Mississippi Public Service Commission (MPSC) disagrees with the Direct LOL approach. First, this approach will assign little to no capacity credit to solar facilities. Billions of dollars have been committed and are planned to be spent on solar development in MISO South. These plans have been ongoing for several years. Proposing an accreditation model at this late stage that devalues and undermines these energy resources and these welcomed investments is unreasonable and irresponsible.
Second, selection of resources to be used to serve state load is a decision that resides with state regulators and their jurisdictional utilities. Neither MISO nor FERC can direct a state to construct resources using any specific fuel source. MISO’s Direct LOL proposal would do indirectly what it is prohibited from doing directly by undermining investment in solar generation. By marginalizing solar capacity value, Load Serving Entities planning to develop solar facilities will be required to keep older thermal generation on-line, construct new thermal generation and/or construct expensive storage facilities. This is likely to increase, rather than decrease, capital and energy costs to retail customers. MISO has acknowledged in meetings with southern regulators that MISO “prefers” wind generation to solar, believing that these resources are more likely to be developed in the MISO South region. That belief is contradicted by regulator and utility representative statements, state-approved integrated resource plans, uncertainty of future wind turbine technology, and the lack of meteorological conditions that would support economic investment in MISO South.
MISO must review mechanisms used in other RTOs/ISOs (e.g., California ISO) that recognize the capacity value that solar facilities provide. Because solar generation (i) meets capacity needs throughout the day (and at the current peak), and (ii) actually shifts the risk hours to later in the day, its contribution to resource adequacy should be reflected in accreditation. The MPSC prefers an average ELCC to the marginal approach that better reflects the value of solar investments and sends appropriate price signals to develop future solar facilities.
The MPSC offers no comment on the PRM calculation at this point.
AMP, MEC, and MPPA support WPPI's feedback.
I'm happy to discuss.
David Sapper
dsapper@ces-ltd.com
Invenergy appreciates the opportunity to provide comments on MISO’s proposed capacity accreditation reform.
Invenergy continues to believe that MISO’s Direct Loss of Load methodology is the wrong direction for capacity accreditation and is concerned about the potential impact of this “black-box” methodology:
1. MISO has not demonstrated what quantifiable reliability benefits the narrower Loss of Load Hour pool provides over a well-established ELCC hour pool, nor that it incentivizes a “more reliable” set of resources over an ELCC methodology.
2. It is unclear how Loss of Load Hours will be calculated and applied to different class years of resources, which makes the project finance implications impossible to analyze.
3. It is concerning that MISO’s software capability implement a capacity proposal as complex as DLOL has not been addressed, especially considering recent changes in other committees predicated on software limitations.
Invenergy continues to support the Average ELCC methodology due to its (1) input and process transparency, (2) compensation for reliability value provided, (3) feasibility to implement, and (4) substantive record of stakeholder support.
Public Service Commission of Wisconsin (PSCW) and the Office of Regional Markets (ORM) Staff Comments on RASC: Accreditation Reform (RASC-2019-2, RASC-2020-4) (20230228-0301)
At the February 28-March 1 2023, meeting of the Resource Adequacy Subcommittee (RASC), MISO presented updates to the accreditation reform proposal. Stakeholders are asked to provide written feedback on the following:
In providing these comments, it should be noted that many questions remain about how this proposal fits into broader resource adequacy objectives and ongoing state planning and resource decisions. Because resource adequacy is significant to states, our OMS Board Member and PSCW staff will continue to raise issues and questions through participation at MISO and OMS as we discuss this subject.
The initial section of these comments attempts to respond directly to MISO’s feedback request. However, additional time is needed with this proposal and its objectives before we can provide more constructive feedback on the proposed D-LOL method and by not directly addressing certain elements of this proposal, it should not be construed that we endorse an idea or direction. In that spirit, we have also provided several questions and observations in the second section of this feedback we would like to see addressed with this proposal and with MISO’s approach to accreditation reform. ORM staff appreciates the opportunity to share these thoughts as well as the recent educational opportunities like March 17, 2023 Energy Systems Integration Group (ESIG) workshop and we request additional education and discussion opportunities for this topic going forward.
Section 1: Response to MISO Feedback Request Items:
ORM staff considers that MISO should continue its approach of having a two-step accreditation process: (1) “Class-level”, and (2) “Unit-Level”. While we recognize the simplicity of only utilizing historical data (i.e., Resource Adequacy Hours as established in Schedule 53), we consider that it lacks the forecasting piece of accreditation. The Direct-LOL method might not be the best, however, we consider it important to have a probabilistic analysis method of some sort that assesses the variability of weather-dependent resources.
As described in the ESIG presentation, by having a two-step accreditation of probabilistic analysis and tight margin hours, the following risks are then better captured (or reinforced):
On a “Class-level” and “Unit-level,” our staff recommends to MISO that the LOL hours accreditation method to be scoped at a sub-regional level. The resource potential for solar and wind resources, and other resources to be included, is highly different between MISO North/Central and MISO South. For example, the solar resource availability is not the same in Wisconsin and it is in Mississippi. It is for this reason that we suggest MISO to bifurcate the LOL hours between MISO North/Central and MISO South.
ORM Staff considers that if MISO moves ahead with an accreditation approach that focuses on LOL hours, it will have to change its PRM calculation as well. The PRM calculation should no longer be calculated based on seasonal coincident load peak hours, rather, it should be calculated based on seasonal coincident risk peak hours. This should reflect the proper shift of risk periods to later hours in the diurnal cycle.
The calculation of the PRMR based on coincident risk, rather than coincident peak, allows for an adjustment in the PRMR that could benefit LSEs. However, the low accredited solar could negatively impact Independent Power Producers (IPPs) that would aim to serve capacity. An aspect that is not accounted for in the shift of risk hours by adding more solar is that the magnitude of the local peak has decreased. Hence, these solar resources that would have received near zero capacity credit are still helping in ‘shaving’ demand because of their ability to serve energy. We ask MISO to include this attribute in its accreditation method, in order to send related market signals for this described benefit.
We would also like for MISO to further confirm or refute the following questions:
On a similar approach as with the MISO LRTP workshops, we recommend MISO conduct Accreditation and LOLE Study workshops purposed for all stakeholders. It would be highly beneficial if stakeholders could attend a workshop from a teaching perspective.
For example, it would be very helpful if MISO RASC and LOLEWG establish a workshop that teach stakeholders on a fundamental basis how are the PRM and PRMR calculated in the LOLE model and include projections of these two values as (1) risk periods shift, and (2) season correlated outages are better estimated.
Section 2: Response/Questions relating to MISO’s Accreditation Proposal
The following comments, open questions, and recommendations are meant to illuminate some concerns and generate ideas that can move this process forward. In the stakeholder process, we are hearing from stakeholders, including from vertically-integrated states, LSEs, and others that the marginal method could be very challenging. We believe by facing that challenge with additional options and ideas, we can collectively navigate to a workable solution for MISO and stakeholders.
1) MISO needs to appreciate the tension and address the fact that with most of the load in the MISO being served by vertically-integrated utilities with state-required reserve margin requirements or approved resource plans, the D-LOL marginal approach is only looking at one side of the equation. If an LSE has built a load-serving plan based on advanced modeling / integrated resource planning of their 8760 hours of expected load, and identified the resources that most cost-effectively serve that load in all hours, then we must recognize how detrimental it would be to de-value the contributions of any resource that is used to meet that LSE’s load. For example, if a 1,000 megawatts of solar facility is determined to be the most cost-effective contribution for an LSE to meet its load, but an updated accreditation method adjusts that capacity to 10% and therefore concludes the LSE is massively short (say 600 MW short, based on the capacity accreditation changing from 70% to 10%), that result does not match the reality of that LSE’s 8760 hour load serving plan. However, we understand that a forward-looking signal may need to be different than the signal being sent today based on capacity accreditation.
2) MISO has attempted to describe how the D-LOL marginal method will result in reduced planning reserve margin requirements for the LSEs. It would be helpful if MISO would better explain how this works and describe how that reduced requirement will be a benefit that accrues to LSEs who have made investments in renewable resources, in particular solar. This should be explained in megawatts and dollars with some solid examples.
3) Two different accreditations and/or two different processes may be needed. Attempting to use one accreditation value to do many things simply may not work. Recognizing, as described above in 1), that an LSE who has built a plan to serve customers across all hours should not have their cost-effective resources de-valued. However, also recognizing that a different, forward-looking value may be needed to signal the value of various generation or demand-side resources in the future.
Some stakeholders have suggested that these two different values could be utilized in two different time-scales / processes: an average / “current” value for meeting today’s load, which could be used in the prompt year auction, yet a marginal/forward-looking value for meeting tomorrow’s expected load, in (as stated by one stakeholder) a 3-year forward auction.
Another way to split this would be “vintaging” the existing LSEs resources from the future resources. We understand FERC did not approve that in NYISO, and we will need to review that decision. However, MISO, being mostly vertically-integrated, may require a solution that did not work for a different, competitive, deregulated ISO. Vintaging could enable LSEs to get accredited capacity for building resources that meet their load, and have that value locked in for the duration of the investment. A big challenge arises if capacity value is reduced while the investment is still doing its job: it may paint a false picture that a resource is a stranded asset.
We are not specifically advocating for a separate auction or vintaging at this time because we have not evaluated the various pros and cons; however, we would like to use these ideas to better illuminate the problem, and why the D-LOL method does not appear to be a panacea.
4) An alternative to having two different accreditations could be modeled after some work from Wisconsin. In Wisconsin, in an effort to appropriately value “avoided costs” as part of PURPA dockets, PSCW staff concluded that an “increment-decrement” approach was more appropriate. This approach looks both at the cost of the most recently-procured capacity and energy, as well as the cost of the next/future capacity and energy resource that would be procured, in order to set a more appropriate “avoided cost.” This concept could be augmented for this present quagmire, but again, this suggestion is not an endorsement of this idea, but a potential idea for MISO and stakeholders to think about and build toward a more constructive approach.
5) We would like MISO to better explain and reconcile why the probabilistic RA hours are not matching up with Max Gen hours, as mentioned on the last RASC and/or ESIG webinar. We are concerned that the RA hours are not lining up with real needs or risk, and therefore sending an inaccurate signal about when capacity is needed and/or valuable.
6) With Futures expectations, driven by electrification assumptions, that winter loads are expected to increase, MISO should more holistically explain how wind energy will be affected by these changes as well. The conversation seems to be focused on solar at this time. However, the RRA shows a huge amount of wind resources could be built all throughout MISO to meet energy requirements in future years.
7) MISO needs to recognize that we are in the midst of two major RA changes / events, for which we not had data to evaluate the impacts of those events, and yet we are stacking similarly-impactful proposals on top of them. We do not yet know the impact of either a) the PRA clearing at CONE and signaling a capacity need in multiple zones in MISO North, or b) the seasonal auction being run for the first time. When Zone 7 cleared at CONE a few years back, Michigan took action to make changes. We do not yet know how the other Zones in the North are responding to the CONE signal, and we likely will not know until after the 2023-24 PRA is run and evaluated. At the same time, we will also get our first evaluation of the seasonal auction this year. We need time to sift through and evaluate these results in Summer/Fall 2023. MISO should prioritize a transparent, stakeholder-inclusive evaluation with workshops and webinars to discuss the impacts and results of these two large changes. This would be consistent with a more scientific method of evaluating changes, before stacking new changes on top of them.
Comments Submitted on Behalf of The MISO Cities and Communities Coalition participants
To: The Resource Adequacy Subcommittee
Re: Accreditation Reform
The MISO Cities and Communities Coalition (MISOCCC) appreciates the opportunity to submit this feedback to MISO on its resource accreditation reform proposal. MISOCCC is a coalition of communities[1] across the MISO footprint that coordinates collective action to further the individual clean energy, economic development, decarbonization, affordability, and grid reliability goals of participating communities through engagement with MISO leadership, its staff, and its stakeholders.
MISO’s resource adequacy (RA) construct design has a direct impact on the ability of MISOCCC members to achieve their respective energy goals as the RA construct sends a fundamental investment signal to the region’s utilities that serve MISOCCC members. As such, we strongly urge MISO to adhere to the core principle of compensating resources based on their reliability contributions. MISO must demonstrate clear ties between reliability value and compensation for resources.
Key Design Principles for RA Reforms
One critical component of the design construct which will directly impact the tie between compensation and reliability value is the selection of risk hours to be used in the capacity credit calculation in MISO’s proposed Direct Loss of Load method. We urge MISO to fully explore all available risk hour selection options and share the full results of this analysis with stakeholders.
We disagree that the proposed reforms would maintain or improve reliability in the face of increasingly frequent extreme cold and heat weather events. Solar energy can provide reliability value during extreme heat events, and MISO’s construct should recognize that. Further, pairing energy storage with generation of all types adds flexibility and value to the grid and should also be appropriately accredited.
Fair Credit to All Resource Types
MISOCC urges MISO to ensure its RA construct is fair for all resources, including distributed energy resources (DERs) as well as large-scale renewables, storage, and hybrids. DERs are a core component of many MISOCCC members’ energy goals, expanding our ability to procure clean energy resources when our local utilities are unable to meet that need. Consistent with FERC Order 2222, in which DERs must be compensated for the value they bring, MISO’s RA construct must ensure these asset types and the retail programs through which they participate in MISO are fairly and fully valued.
MISO’s RA construct should accredit all resources comparably, using the same methodology and evaluating reliability contributions during the same hours of risk, in line with the Energy Systems Integration Group’s Ensuring Efficient Reliability: New Design Principles for Capacity Accreditation.[2]
MISO’s current proposal undervalues renewable and other clean energy resources, which MISOCCC members are relying on to meet our energy goals while maintaining grid reliability. As written, MISO’s proposal is in direct conflict with public policy goals and our desire to maximize the economic value of clean energy and distributed energy resources because the proposed accreditation would favor building out a new generation of gas plants rather than renewables and energy storage. We urge MISO to avoid making arbitrary assumptions on hybrid and storage asset behavior and instead embrace the flexibility of these resources to respond to market signals in Day Ahead and Real Time to provide reliability value to the MISO region. It is critical to link RA accreditation with real-time operational performance during periods of reliability risk to ensure the RA construct efficiently meets the regional reliability needs.
Thank you for considering our feedback. We look forward to continuing to work with MISO and stakeholders to ensure MISO’s wind and solar accreditation reforms are aligned with the policy and reliability needs of MISOCCC members and the region more broadly.
Sincerely,
The MISO Cities and Communities Coalition
Jeremy Caron
Sustainability Program Manager
City of Des Moines, Iowa
Missy Stults
Sustainability and Innovations Director
City of Ann Arbor, Michigan
Jason Ludwigson
Sustainability Coordinator
City of La Crescent, Minnesota
Kim Havey
Director, Sustainability
City of Minneapolis, Minnesota
Russ Stark
Chief Resilience Officer
City of Saint Paul, Minnesota
Wisconsin Local Government Climate Coalition
Representing 17 Wisconsin Local Governments
[1] For the purposes of coalition membership, the term “community” is defined as city governments, county governments, tribal nations, regional planning commissions, etc.
[2] A Report of the Energy Systems Integration Group’s Redefining Resource Adequacy Task Force. https://www.esig.energy/new-design-principles-for-capacity-accreditation/. Feb. 2023.
MidAmerican appreciates the opportunity to provide feedback on MISO’s proposed accreditation reforms. (RASC-2019-2, RASC-2020-4) (20230228-0301)
MidAmerican is very concerned about MISO’s proposed accreditation reforms. The concerns are below.
– Provide typical expected forced outage rates/availability for each resource type
– Provide expected capacity accreditation values for each MISO zone (or state) for each resource type
– Provide forecasts of how planning reserve margin requirements change over time with various resource mixes
– Provide forecasts of how regional transmission expansion impacts resource planning parameters; specifically provide forecasts of how the Long-Range Transmission Plan and Tranche 1 may improve capacity accreditation, reduce reserve margins, or otherwise mitigate Direct LOL risks
WPPI Energy is not offering an opinion at this time on whether to adopt a Direct LOL methodology (our previous comments dated 11/4 and 12/30, which describe our comfort with the existing wind accreditation methodology, stand), but we offer the following comments for MISO to consider in the event that MISO proceeds with a Direct LOL approach.
Regarding LOL accreditation methodology, MISO describes a variety of simulation- and historical-based approaches to determining resource output during high LOL hours. We appreciate the efficiency of being able to use a purely simulation-based approach in conjunction with the PRM determination. We do think, however, that it might be more appropriate to consider not only those hours that experienced LOL in the Monte Carlo simulation, but also other hours that experience low margin in those simulations, or that otherwise exhibit material LOLP, and to calculate some kind of weighted-average resource output weighted by that LOLP. We do have some concern as to whether simulated non-thermal resource availability accurately captures actual resource characteristics. Accordingly, we see potential benefit in incorporating historical output. We are not able to opine intelligently on this question with the information provided to date, however. We would request that MISO develop and share more information on how historical-based and pure simulation-based numbers compare, and we think this information would be necessary to give stakeholders confidence in the simulation-based approaches.
Regarding the Planning Reserve Margin calculation, and the load level on which this is based, it appears to us that we could either continue to use peak gross demand or select some other demand level, such as peak net demand. It appears to us that there might not be a large difference in these approaches, at least to the extent that the load profiles MISO uses in its PRMR analysis are realistic. Given the abbreviated discussion of this topic at the last RASC, however, we would request that MISO share more details of its thinking on this topic with stakeholders, including potential problems that MISO anticipates we may experience if we stick to the peak-gross-demand approach, or advantages of an alternative approach. We would be better able to provide meaningful feedback after such a discussion.
Environmental Sector Comments on Accreditation Reform
(RASC-2019-2, RASC-2020-4) (20230228-0301)
The Environmental Sector Continues to Have Strong Misgivings About MISO’s Current Path
As an initial matter, we refer MISO back to our previous two rounds of feedback, submitted November 2 and December 21 of last year; most of the concerns and questions raised in those comments remain relevant to MISO’s most recent presentation on capacity accreditation.
We continue to have serious concerns about how MISO is approaching the question of capacity accreditation. We still believe that the core purpose of the Planning Resource Auction (PRA) is, and should remain, a tool first to identify reasonably prompt capacity needs, and then to identify and compensate generators or other resources that are necessary and available to meet those needs. There are other tools available to MISO to help it guide long-term utility resource planning, including through energy markets; it should evaluate and utilize some of those alternative tools.
MISO Should Not Rely Exclusively on a Flawed LOLE Model to Determine Capacity Accreditation
If MISO does move forward with something resembling the Direct-LOL method, at the very least it cannot continue with its proposal to rely exclusively on the LOLE study to determine the fleet-wide accreditation of each of the resource classes. There may not be a significant theoretical divide between looking at future projected risk hours (LOL hours) or past actual risk hours (RA hours); but in practice there is a chasm: MISO’s LOLE study is simply not capturing the most significant risk hours effectively, because it is apparently not able to capture the severe weather events that have caused many of MISO’s most significant scarcities in recent years. Over the past few years, the LOLE study has a remarkably poor track record for predicting high-risk hour events, particularly in the non-summer seasons: based on data from PY 18-19 to PY 21-22, there was less than 1% overlap between LOL Hours and MaxGen hours during the three non-summer seasons, even during major events such as Winter Storm Uri or the 2019 Polar Vortex. And the model’s performance is not significantly better during the summer, when there was only a roughly 15-20% overlap between the summer MaxGen and LOL hours.
Season | RA Hours not covered by LOL Hours | Max Gen Hours not covered by LOL Hours |
Spring | 99.7% | 100.0% |
Summer | 80.0% | 85.7% |
Fall | 99.1% | 100.0% |
Winter | 99.5% | 100.0% |
We do note and appreciate that MISO recently modified the LOLE model to attempt to capture temperature-correlated winter outage risk among thermal units. This is a much needed change that will hopefully improve on the LOLE study’s particularly poor track record for predicting high-risk hours in the winter season; but the change has not yet been stress-tested against actual winter events, and does not address the model’s underperformance during the other three seasons. In short, MISO has provided no evidence demonstrating that its LOLE study methodology (even with recent improvements) can accurately simulate winter events, or that the extremely poor overlap between LOL hours and MaxGen/RA hours during the non-winter seasons won’t continue going forward. And this is important because any accreditation methodology that MISO moves forward with must be able to show that it is capturing the kind of real reliability events that MISO is seeking to protect against with its resource adequacy requirements.
We discuss further below the ways in which MISO needs to allow stakeholders the opportunity to weigh in far more specifically on the LOLE model so that we can offer improvements; but more broadly, it is not defensible to base an entire resource class’s capacity accreditation on the outcome of a model that currently so wildly fails to predict actual risk hours. It is also inconsistent with MISO’s fifth Market Design Guiding Principle, as shared on slide 8 of the March 1 Accreditation Reform presentation, which states MISO’s intention to “[m]aximize alignment of market requirements with system reliability requirements;” and with the “Impact” and “Stability principles presented on slide 8 of that same presentation.” Even though MISO is considering using the same accreditation methodology for all resource types, an approach that captures weather-related correlated outages for some resource classes and not for others cannot be said to result in comparable treatment.
Fortunately, we also note that Slide 9 of MISO's presentation discusses various accreditation design options, including three alternatives that move MISO away from exclusive reliance on LOL Hours. We support MISO’s apparent intention to look at multiple design options and fully support continuing this conversation in future RASC and other meetings and workshops. However, MISO needs to share more information about Design Options 3 and 4 (combining LOL Hours with MaxGen Hours, and improving the LOLE model to account for “tight margin hours”). And MISO should evaluate the following additional Design Options as part of this discussion:
Additional combinations of measurements, such as combining RA and MaxGen hours
Using an accreditation approach that is based solely on individual generator performance and doesn’t socialize risk within a particular resource class
As it leads this stakeholder discussion and conducts its analysis, MISO should establish clear decision criteria. MISO has established some principles for this work, but there is no indication of how and what metrics MISO will use to decide which Design Options is preferable. One or more validation criteria are needed, such as comparing the method to actual risk hours, and MISO should solicit stakeholder feedback on what these criteria should be.
Finally, it is important to correct MISO messaging on one point: at various times, MISO staff have suggested that their current accreditation proposal for nonthermal resources mixes both prospective and actual performance, because it allocates the capacity credits within each generation class among individual facilities based on their performance over the previous few years (in RA Hours). We do not agree that this method constitutes a true balance of LOL Hours and RA hours: while both might technically be used in the final capacity accreditation calculation for each individual resource, they are not used in an equivalent manner, because the calculation does not account for the (relatively common) situation in which an entire generation class outperforms compared to MISO’s projections. For instance, wind resources performed well as a class during Winter Storm Elliot, but this was not reflected in the overall accreditation that resource class received. Fundamentally, if a type of generation (e.g. all renewable or all thermal resources) performs better during high risk hours than MISO predicted, those resources’ collective accreditation should not then remain limited by MISO’s inaccurate projections, and be adjudged based on its performance during hours that MISO incorrectly believed would be high risk. And that problem is not solved simply by allowing overperforming individual generators to compete with each other for an unacceptably small overall amount of capacity credits. Thus, if MISO is serious that it wants to incorporate both RA Hours and LOL Hours (both retrospective and prospective, both deterministic and probabilistic) into any accreditation regime, it must do so at the class level, and not by bisecting the calculation so that actual availability in high-risk hours only impacts the amount of the class-level pool of capacity credits that is allocated to individual generators.
MISO Need to Better Explain Several Crucial Aspects of Its Current Proposal
In addition to our general concerns, we have a series of questions about the practical application of a Direct-LOL approach that MISO has not adequately addressed. A list of some of the most important questions we have follows:
Slide 10 of MISO’s March 1 presentation underscores how important it is to correctly calculate Planning Reserve Margin (PRM), but provides no detail on how it would do that. As a result, MISO still has not articulated precisely how seasonal PRMs would be determined: which LOL hours from the LOLE model would be used, and how would a PRM be derived from those hours? (For example, will any LOL Hour in any sample be used and weighted against the total number of runs, or would MISO only use those that occur in a minimum number of samples?) Stakeholders need this information sooner than later to help us judge the impacts of MISO's proposal.
MISO has not articulated how it would evaluate “applicability” of Direct LOL to other non-renewable resources.
MISO has not explained how a marginal accreditation approach is supposed to be used by Load Serving Entities (LSEs), each of which has its own unique mix of resources, and apply those accreditation values to planning processes that typically require consideration of both existing and new resources’ capacity values. For example, if a thermal unit is retired, how does that affect the accreditation of any generator within the LSE’s portfolio or MISO more broadly, and how should that future impact be considered? It is critical that any accreditation approach adopted by MISO can be reasonably incorporated into utility resource planning analysis.
MISO needs to explain how it will address the iterative kind of analysis suggested at the ESIG workshop whereby it is supposed to be checking whether the PRMR has been met by the actual set of resources that clear the PRA.
We Support MISO’s Proposal to Include Thermal Generation in This Round of Accreditation Reform; MISO Should Also Include Hybrid and Storage Resources
One aspect of MISO’s proposal that we unambiguously support is MISO’s current stated intention to include Schedule 53 (thermal) resources in this current round of accreditation reform and to treat all resources equivalently. While this commitment does not alleviate the concerns shared above, we see it as a step in the right direction and support MISO’s move towards an accreditation approach that treats all resources equivalently. As such, we urge MISO to continue on this pathway and only consider capacity accreditation solutions that apply equally to all resources (and would be implemented concurrently for those resources).
Furthermore, since MISO is in the middle of evaluating a comprehensive capacity accreditation reform for multiple resource types it should take this opportunity to also include two additional resource types. Both storage and hybrid generation facilities (especially solar-storage paired projects) are being built at a rapid rate, and represent a rapidly growing share of the available resources in the MISO region. MISO has committed to introducing a capacity accreditation for both resource types following this proceeding, but may find it difficult to pursue a separate accreditation methodology for two additional resource classes after confirming in this proceeding that all resource types must be evaluated equivalently. We’re concerned that if their accreditation is not addressed here, MISO will face three universally unpalatable options: either shoehorn storage and hybrid resources into an accreditation methodology that didn’t specifically consider their unique characteristics; redesign resource accreditation across the board yet again; or create a separate resource accreditation methodology that raises the same differential treatment concerns MISO is trying to resolve now for nonthermal vis-à-vis thermal resources. MISO needs to provide businesses and developers with long term certainty as to how their projects will be accredited, and none of those three options can provide that certainty. Thus, MISO should add hybrid and storage facilities to its broader efforts here.
Accreditation also must work with the larger resource adequacy construct and any other market mechanisms that seek to incentivize resources to show up in the PRA and in real time, such as scarcity pricing, and the proposed shift to a reliability-based demand curve. As our sector has suggested in the past, MISO must look at all of these mechanisms to ensure reliability in a comprehensive manner.
MISO Should Take Seriously the Transparency Motion and Work to Comply in a Timely Manner
MISO is no doubt aware that the transparency motion sponsored by the Environmental Sector at the February 28 / March 1 RASC meeting passed without a single dissenting vote. We believe this result underscores the widespread concern that MISO has not shared enough information with stakeholders to allow us to adequately weigh in on the various proposals that it has shared. And as such, we hope MISO takes seriously the need to open up its proverbial doors even further to allow stakeholders, including but not limited to the Environmental Sector, to understand how these proposals are coming together and what their impacts would be.
In service of that goal, and in the interest of helping MISO identify how to make itself even more transparent, we have developed a list of documents we think could help the ongoing accreditation discussion. We believe MISO could fulfill the intent of our motion by providing the following:
A backcast of a recent extreme weather event with load shed in MISO’s system that shows how the revised LOLE approach aligns with the actual risk hours, with the results shared at the lowest level of aggregation needed to make the data public (i.e., to avoid sharing confidential information);
The LOL Hours identified on slide 12 of MISO’s January 18, 2023 presentation to the RASC on Non-Thermal Resource Accreditation (Item 14b);
Any data showing steps MISO has taken to align its LOLE approach with actual outage risk exhibited on its system (not just in winter);
The representative wind and solar profiles that MISO uses in its LOLE study; and
Any additional SERVM data MISO has in its possession that it is able to share.
Any analysis MISO has in its possession showing the impact of the Direct LOL based approach in years between today and 2041 (slide 5 of the March 1 presentation)
Importantly, this is not an exhaustive list of information that may become necessary to share with stakeholders; it is simply our best first attempt at identifying such information. However, it would represent a meaningful step forward from previous practice. We request that MISO provide a response to stakeholders at the April RASC meeting about how they plan to meet these requests for increased transparency.
MISO Should Continue to Receive Regular Feedback from Stakeholders
Finally, we note that MISO did not provide an opportunity for feedback after its January 18, 2023 RASC Meeting. Given the complexity of MISO’s proposed accreditation reforms, the rapid rate of change in its proposals, and the outsized impact this policy will have on all stakeholders, we believe MISO should seek input from stakeholders as often as it provides updates on its thinking. A fully iterative and open communication process is MISO’s best tool for developing a capacity accreditation proposal that has the highest level of stakeholder support.
Michigan Public Power Agency (MPPA) refers MISO to the Stakeholder Motion on Data Sharing and Transparency from the 2/28/28 – 3/1/23 RASC, which passed unopposed with 56 votes in favor (and 1 abstention). MPPA urges MISO to accept this unambiguous message from the Stakeholder community that we need the data and analytical support behind MISO’s accreditation proposals before we can judge whether to support them. - Tom Weeks, Wholesale Markets Lead, MPPA
Submitted on behalf of East Texas Electric Cooperative, Inc. (ETEC):
ETEC appreciates the opportunity to submit the following comments and requests to MISO:
ETEC reiterates its concerns related to MISO’s pace of change and transparency around resource adequacy concerns as voiced in its Reliability-Based Demand Curve feedback, as they are also applicable to Accreditation Reform. MISO and its stakeholders need to understand and appreciate the impact of MISO’s recent reforms through the results of the upcoming 2023/24 Planning Resource Auction. Furthermore, MISO should increase the transparency behind its reform efforts by developing a design document that details MISO’s reforms and providing supporting data and calculations.
Although MISO’s accreditation reform discussions have been somewhat limited to wind and solar thus far, ETEC understands that any reform could be ultimately extended to all resources, including thermal resources which just had their accreditation methodology significantly altered. As a part of a design document, MISO should specify its current thoughts and plans for accreditation reform beyond just wind and solar so that stakeholders can understand the complete picture of accreditation reform. MISO should further justify why additional modifications to thermal resources should be made given the lengthy discussion and effort put into the prior reforms. If MISO is going to proceed with accreditation methods that vary by resource technology/type, then MISO should include a long-term plan for aligning accreditation methods or justification for why different approaches are appropriate.
If MISO were to proceed with a Direct LOL accreditation approach, ETEC would like to understand the broader impacts of such a shift. ETEC understands that there are certain reliability risks (e.g., correlated cold weather outages, imperfect outage scheduling, etc.) that are effectively socialized across the Planning Reserve Margin (PRM) determination. Under a Direct LOL accreditation paradigm, those risks would conceivably be accounted for in class/unit accreditation. Under the RA Hours approach for thermal resources, MISO currently applies a scaling factor to restore the aggregate quantity of thermal accredited capacity to the UCAP level, but presumably under a Direct LOL approach that step would be replaced based on the Direct LOL class capacity determination. When discussing marginal vs average ELCC, MISO presented information on how the Planning Reserve Margins might shift, based on risk being accounted for differently under a marginal approach. ETEC strongly believes that a forward view of the seasonal PRMs should be included as a part of any accreditation reform discussions. Resource accreditation and reserve margin modeling must function collectively to achieve reasonable resource adequacy outcomes.
WEC Energy Group encourages MISO and stakeholders to consider the direct application of Schedule 53 to accredit all resource types (for use in MISO's RA construct which may differ from capacity value within long-term resource expansion planning at the state level). Schedule 53 is already in place for non-intermittent resources and is easily applied to intermittent resources. MISO and stakeholders expended significant time and effort developing the Schedule 53 process and definition of hours when resources are most needed. We should leverage that work and accredit all resources fairly and comparably based solely on their actual performance when they are most needed.
We acknowledge that certain provisions are needed to accommodate the accreditation of intermittent resources based on Schedule 53. Unlike thermal resources that are modeled within the LOLE study at an ICAP with a forced outage rate, wind and solar resources are modeled with an hourly energy profile, representing their expected availability during Tier 1 and Tier 2 hours. The resulting Planning Reserve Margin already accounts for the expected availability of wind and solar resources – no adjustment to their ISAC value is needed (or alternatively, the UCAP/ISAC ratio for wind and solar is 1.0). As noted in testimony accompanying MISO’s seasonal resource adequacy proposal, a UCAP/ISAC conversion ratio is needed for thermal resources to ensure alignment with the Planning Reserve Margin from the LOLE model because thermal resources are not modeled based on their performance during Tier 1 and Tier 2 hours. Rather, thermal resources are modeled at their ICAP and an associated forced outage rate, which MISO has demonstrated does not always capture their availability when they are most needed. Since the LOLE model and resulting Planning Reserve Margin already reflects the hourly output profiles for wind and solar resources during Tier 1 and Tier 2 hours, no UCAP/ISAC adjustment ratio is needed for wind and solar (or alternatively, the ratio is 1.0).
WEC Energy Group is concerned that use of direct-LOL results in an accreditation for an entire resource class based on the modeling parameters and assumptions within the LOLE study. Those modeling assumptions and parameters will directly influence accreditation. While MISO's proposal would distribute the total direct-LOL accreditation MWs of a resource class to individual resources based on relative historical performance, the total accredited MWs for the resource class is still based on the LOLE model. Each individual resource should have the ability to demonstrate its own value during Tier 2 hours (RA Hours) based solely on its performance rather than on an allocated portion of the total direct-LOL MWs of the resource class. Each resource is then accredited fairly and comparably based solely on its performance when it was needed most, regardless of whether it is intermittent or not and regardless of the myriad of assumptions that are required to determine the direct-LOL of a resource class.
Response of the Solar Energy Industries Association
The Solar Energy Industries Association (SEIA) appreciates the opportunity to submit these stakeholder comments in response to MISO’s accreditation reform proposal.
SEIA is very concerned that MISO’s current proposal could lead to unduly discriminatory outcomes while also undermining resource adequacy in the MISO region. As MISO states in its March 1 presentation, it anticipates a rapid increase of solar penetration in the region, with 23 GW of executed solar interconnection agreements not yet in-service. In response to this rapid resource mix change, MISO proposes a direct loss of load accreditation methodology for wind, solar, and hybrid resources.[1] Thermal resources will still be accredited using the Seasonal Accredited Capacity (SAC) methodology. The March 1 presentation included an illustrative example of how the direct loss of load methodology would affect capacity values of wind, solar, and hybrid resources. In that example, the capacity value of solar PV would be 0% by 2041.[2]
MISO’s proposal presents three issues that must be resolved through these stakeholder proceedings. First, the present proposal is likely unduly discriminatory. Wind, solar, and hybrid resources would be accredited using direct loss of load while thermal resources will still be accredited using the SAC methodology which relies, in part, on Unforced Capacity (UCAP). By using a methodology that relies on UCAP, MISO’s accreditation of thermal resources will fail to acknowledge the correlated outages from these resources. By ignoring these outages, MISO will continue to overvalue thermal resources, despite the evidence demonstrating that thermal resources may not be able to perform during times of need.[3]
Second, the proposal is inconsistent with MISO’s statements regarding Dispatchable Intermittent Resources (DIRs). In its recent FERC filing in Docket No. ER23-1195, MISO states that it “recognizes the value of DIRs, and is committed to supporting their growth.” By its own admission, MISO’s capacity accreditation proposal could result in a capacity value of 0% for solar resources by 2041. It is hardly possible to support the growth of DIRs when while attributing no value to those resources.
Finally, the proposal is inconsistent with MISO’s planning principles. There are five guiding principles to MISO’s market design.[4] Principle two provides that market design should “Facilitate non-discriminatory market participation regardless of resource type.” Yet, MISO will be applying two different resource accreditation methodologies for renewables and thermal generators, even though recent evidence suggests that doing so will result in the overvaluation of thermal resources. Principle three provides that market design should “Develop transparent market prices reflective of marginal system cost.” Yet, accrediting thermal resources without taking into account unenforced outages will result in consumers paying for capacity that may not be provided during the times it is most needed, resulting in a market price that overvalues certain resources.
In order to ensure a market design that is consistent with MISO’s planning principles and does not result in the unduly discriminatory treatment of renewables, SEIA suggests that MISO adopt the following changes to its proposal. MISO should apply the same accreditation methodology for both renewable and thermal resources. That accreditation methodology should be Effective Load Carrying Capacity. MISO should not use a direct loss of load accreditation methodology. SEIA considers direct loss of load to be a marginal approach that will not appropriately value the capacity contribution of solar to meet peak load. MISO should also expand the loss of load hours to the Schedule 53 definition of hours when resources are most needed. Implementing these reforms will help ensure that MISO’s proposal is just and reasonable while also protecting resource adequacy in the region.
A marginal-only approach does not fairly represent the contribution value of all resources in the portfolio. Resources like solar need the recognition of offsetting the gross peak and core LOLE risk, in addition to offsetting the net peak and remaining marginal LOLE risk. Other thoughts:
March 15, 2023
To: MISO Resource Adequacy
From: Southern Indiana Gas and Electric Company d/b/a CenterPoint Energy (SIGE, SIGW)
Subject: RASC: Accreditation Reform (RASC-2019-2, RASC-2020-4) (20230228-0301)
Thank you for the opportunity to provide feedback on the accreditation reform currently underway at MISO for non-thermal resources.
SIGE/SIGW, understands that MISO is planning to file the Direct-LOL method with FERC in Q4 2023. Prior to this filing, LSEs should have access to detailed accreditation methodology and associated calculations for each of our generating units so that the company can make informed, timely comments to MISO about the proposed methodology prior to MISO seeking approval from FERC for Direct-LOL.
Regards,
Kimberly Dunning
Manager, MISO Affairs