In the August 22-23, 2023, meeting of the Resource Adequacy Subcommittee (RASC), MISO presented updates to the accreditation reform proposal including a Planning Reserve Margin Requirement (PRMR) strawman proposal and Schedule 53 Tariff redlines. Stakeholders were asked to provide feedback.
Comments are due by September 8.
Minnesota Power appreciates the opportunity to provide stakeholder feedback.
The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback on MISO’s accreditation reform proposal. The EOCs continue to believe that Average ELCC is the correct methodology to be used for accreditation in MISO’s prompt year PRA because it more accurately measures the reliability contribution for existing resources than the DLOL methodology.
Stakeholder Presentation DLOL Recommendations
The EOCs support the three DLOL improvement recommendations offered by Next Era, Invenergy, and Astrape. These recommendations are:
The EOCs request that MISO perform analysis on these proposals and ultimately include these proposals in the final DLOL FERC filing, even if it requires MISO to extend the original FERC filing target date into 2024.
Direct-LOL Resource Class Results
MISO has stated that the reason for the low wind winter accreditation value is that 85% of total winter LOL hours occurred in a single weather year, 2021. The EOCs do not believe that one of the 30 weather years should be able to have such an outsized impact on the final accreditation results. The EOCs believe MISO should revise the DLOL methodology so that there is a limit to how much one weather year can impact the class average accreditation rating, which would result in a more stable accreditation methodology.
MISO PRMR Reallocation Proposal
The EOCs are seeking more information to understand MISO’s proposal. The LOLE model does not currently have 8760hourly input data representing each LSEs’ load (the model only uses coincident peak values, not 8760 LSE hourly profiles). This being the case, how does MISO intend to use the LOLE model for purposes of deciding how to reallocate requirements on an LSE-by-LSE basis? Given the disconnect between historic actual load data and LOLE modeling, the EOCs are concerned about using loss of load hours from the LOLE model in combination with historical actual LSE load data. Moreover, given the volatility that LSEs already face with unit SAC ratings, the EOCs are concerned about the added year-to-year volatility and uncertainty associated with MISO’s PRMR reallocation proposal.
LRZ Local Clearing Requirements
The Local Clearing Requirement should no longer be established on a UCAP basis. To determine each LRZ’s local clearing requirement, MISO should calibrate the zonal LOLE model to the 0.1 LOLE target and then sum up the LRZ’s DLOL capacity and the 0.1 LOLE MW adjustment. This will appropriately result in a LCR requirement on a DLOL basis.
The current MISO process for determining local clearing requirements is flawed because LCRs are established on a UCAP basis even though capacity is accredited on a SAC basis. For MISO wide requirements, UCAP and SAC are equal in magnitude so there are no problems with substituting one methodology for the other, but this is not true on an LRZ basis. Some LRZs’ total UCAP is greater than SAC while other LRZs’ total UCAP is less than SAC. The result of this LCR design flaw is that in some cases the MISO LRZ LOLE models will identify a set of resources that are able to meet the 0.1 LOLE target, but the sum of that group of resources SAC values minus the ZIA will be less than the LRZ’s UCAP LCR. This result defies the purpose of using an LOLE model to establish an LCR. If the LOLE model determines an LRZ is reliable with a given set of resources, then MISO’s resource adequacy construct should reach the same conclusion. The EOCs request that MISO fix this problem for the 24/25 PY.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
Consumers Energy appreciates the opportunity to provide feedback on MISO’s accreditation reform proposal. Consumers Energy generally supports WEC Energy group's comments. Furthermore, Consumers Energy feels that more data should be provided prior to completing a FERC filing on how the calculations are completed utilizing DLOL for accreditation and how utilities will be able to internally calculate accreditation for comparison to MISO's provided accreditation to validate proper credit is being provided to each resource.
DTE appreciates the opportunity to provide feedback on MISO’s accreditation reform proposal. DTE is in support of PRMR strawman proposal but would like MISO to better explain how the LRZ DLOL load is being calculated when determining the LRZ DLOL PRMR. With this proposal, it looks as though MISO is moving away from using the coincident peak demand forecast. If that is the case, how is the LRZ DLOL load being updated? Is out-of-date load data from the LOLE model being used determine the LRZ DLOL load?
In terms of DLOL accreditation modeling, DTE agrees with the MISO observation (as well as numerous stakeholders during the meeting), that significant modeling improvements are necessary in order to calculate an accurate DLOL percentage for storage resources. With a significant increase in storage deployment expected in the near future, DTE urges MISO to focus on improving storage modeling as soon as possible. MISO should heavily consider taking learnings from the Astrape presentation pertaining to energy limited resource dispatch and how modeling of batteries can have a large impact on the accreditation of all resource types.
DTE would also like to see the DLOL gas resource class split into two categories: combined cycle, and combustion turbine. DTE sees very different operation in both forced and planned outages of these unit classes and believes they should be separate resources in the DLOL resource mix.
Lastly, DTE requests that MISO provides further case studies showing the results of DLOL accreditation utilizing different resource mixes. Hard data is needed so that all parties involved can have a deeper understanding of the proposal and can give informed feedback to MISO. This will allow MISO to better shape the proposal and benefit all parties. MISO should consider the difficulty in providing supporting data of the DLOL proposal in the process going forward and give themselves more time to provide the necessary data to stakeholders before moving on to the next aspect of the proposal.
AMES, AMP, and MPPA support WPPI's feedback.
Happy to discuss.
David Sapper
dsapper@ces-ltd.com
Otter Tail Power appreciates the opportunity to provide feedback on the current accreditation reform methodology. The August RASC presentation showed “Hour Selection” as the remaining feature being discussed as part of the accreditation reform. Otter Tail is pleased to see that the hours being considered are being expanded to be more in align with the RA hour approach detailed in Schedule 53. This will likely create more consistent signals from the current proposal for resource planning.
However, we would continue to ask that the Resource Classes be accredited on a regional basis. Not only is this a critical component for intermittent generators but also for thermal generators who have potentially implemented different winterization technologies to improve performance during likely times of grid stress. Further yet as was asked during the same presentation by a stakeholder, Otter Tail would be interested in reviewing various gas categories and/or coal. For example, turbine technology (CT/CC); size of turbine; and potentially fuel stored on-site could have drastic improvements/decrements to a resource’s performance within the same class. If data is available to demonstrate the differences in performance, we believe they should be better understood by the stakeholder community.
Otter Tail would appreciate a better understanding of the data that will be required from LSE’s as part of MISO’s straw-man PRMR proposal. Until the process steps for this data input has been provided, it is difficult to fully understand how MISO hopes to achieve what they have set forward in the straw-man. Specifically, is the “measure an LRZ’s load during times of Loss of Load events” done by pulling hourly data from input provided by LSE’s or is it done using the LOLE model using estimates based on regional load shapes? Otter has concerns if it is the latter as our load shape is likely unique compared to our MISO participating neighbors. The third point mentioned in the straw-man mentioned a modification to “true-up” LOLE demand to PRA demand, yet the demand curve set forward in the RBDC proposal comes directly from the LOLE model. Understanding how MISO’s methodology regarding this point will need much more clarification to garner feedback that is helpful to MISO staff.
Comments
of the
Association of Businesses Advocating Tariff Equity (ABATE),
Illinois Industrial Energy Consumers (IIEC),
Louisiana Energy Users Group (LEUG),
Texas Industrial Energy Consumers (TIEC),
Coalition of MISO Transmission Customers (CMTC),
Midwest Industrial Customers (MIC),
and
NIPSCO Large Customer Group (NLCG)[1]
Regarding
RASC: Accreditation Reform (RASC-2020-4, 2019-2) (20230822-23)
September 8, 2023
ABATE, IIEC, LEUG, TIEC, CMTC and MIC, as representatives of the End-Use Customers (EUC) Sector, and NLCG appreciate this opportunity to provide comments to MISO.
During the August 22-23, 2023, meeting of the MISO Resource Adequacy Subcommittee (RASC), MISO presented an update on its Direct Loss of Load (LOL) capacity accreditation proposal for Capacity Resources including a strawman for its proposed change to the allocation of capacity obligations to Load Serving Entities (LSEs) – a proposal that MISO first proposed on July 11-12, 2023 to include in MISO’s forthcoming November 2023 Direct LOL filing with FERC. Our comments herein address MISO’s continued plan to include its proposal to change the allocation of capacity obligations to LSEs in its forthcoming November 2023 Direct LOL filing with FERC and MISO’s associated strawman for its proposed change to the allocation of capacity obligations to LSEs. Specifically, for the reasons detailed in our comments below, MISO’s proposal to change the allocation of capacity obligations to LSEs does not need to be included in its planned November 2023 Direct LOL filing with FERC and needs to be severed from that planned filing in order to ensure any such proposal is just and reasonable prior to being filed with FERC. Therefore, we once again call on MISO to:
Please note our silence with respect to the capacity accreditation part of MISO’s overall Direct LOL proposal should not be interpreted as tacit agreement with that part of MISO’s Direct LOL proposal. In addition, ABATE, IIEC, LEUG, NLCG, TIEC, CMTC and MIC each respectively reserve their right to further comment on MISO’s Direct LOL capacity accreditation proposal in the future.
In our previous July 28, 2023 comments to MISO, we indicated the following:
Despite these comments, MISO at the August 22-23, 2023 RASC meeting indicated that it intended to continue moving forward with its plan to include its proposal to change the allocation of capacity obligations to LSEs in its forthcoming November 2023 Direct LOL filing with FERC. Furthermore, MISO presented a strawman for that proposal that uses a straight average of LSE demand during LOL hours for the allocation rather than a weighted average based on loss of load probabilities and expected unserved energy. As a result, the strawman fails to retain a strong price signal for demand to be suppressed during the very highest firm load shedding risk hours of the year.[3]
MISO’s stated reason for moving forward with its proposal in its November 2023 Direct LOL filing is that it wishes to set capacity requirements for LSEs based on periods with the greatest reliability risk observed in its Loss of Load Expectation (LOLE) model.[4] In particular, MISO argues accreditation reform drives the need for LSE obligations to be better aligned with demands during periods of the highest reliability risk.[5] We do not oppose examining this issue. However, MISO’s urgency with respect to addressing this issue in its forthcoming November 2023 filing is misplaced and the risk of introducing unintended consequences with respect to resource adequacy is great unless sufficient time is provided to carefully craft and analyze any proposed change.
With respect to MISO’s urgency being misplaced, it is important to recognize that MISO’s Schedule 53 capacity accreditation provisions, which are already based on providing capacity accreditation to conventional generation resources at least partially on the basis of their availability during LOL hours, were filed and approved by FERC without any changes to the allocation of LSE capacity obligations. Furthermore, MISO’s Direct LOL capacity accreditation proposal is essentially just a modification and extension of the existing Schedule 53 capacity accreditation provisions to cover all capacity resources. As such, there is no critical need that MISO’s November 2023 Direct LOL capacity accreditation filing simultaneously address changing the allocation of capacity obligations to LSEs. Furthermore, MISO itself has verbally indicated that any proposal that it ultimately makes would be phased in over a number of years. Given all of the foregoing, MISO’s proposal to change the allocation of capacity obligations to LSEs does not need to be part of its November 2023 Direct LOL capacity accreditation filing and can be severed from that filing.
With respect to unintended consequences, it is important to recognize that MISO’s proposed change to the allocation of LSE capacity obligations represents a major change to wholesale cost of service and rate design practices that are over seven decades old.[6] These traditional practices have allocated capacity costs at wholesale on the basis of either annual coincident peak demand or monthly coincident peak demand over a limited number of months. As a result, many LSEs, and their retail customers, have made great efforts, and in some cases have made capital investments, to suppress their load during the time of the system peaks due to the very strong price signal provided by allocating capacity obligations over a very small number of hours of each year. This load suppression is already inherently captured in LSE load forecasts such that, if this current price suppression effect associated with avoiding capacity costs were to be removed, it would likely lead to the appearance of this formerly suppressed demand during the time of the MISO system peaks.
Furthermore, the new price signal introduced by MISO’s capacity obligation allocation proposal would not be effective at suppressing load during the most critical firm load shedding risk hours of the year, whether they be at the time of the MISO system peak or during other hours. This is because the price signal would be diminished by having the allocation of the capacity spread over a relatively large number of hours rather than being concentrated in the most critical few hours of the year with respect to firm load shedding risk. This problem is aggravated by the fact that MISO’s proposal would not only use a relatively large number of hours for the LSE capacity allocation, but would also compound the situation by using an even weighting for all of those hours. This approach fails to consider that certain LOL hours have a much higher loss of load probability and expected unserved energy level than other LOL hours. Applying an equal weighting to all LOL hours risks diluting the critical peak pricing signal to an extent that it could adversely impact the supply-demand balance in the MISO capacity market.
Moreover, MISO has not demonstrated that each LOL hour is of equal significance in determining the contribution of individual LSE loads to the incurrence of capacity costs in MISO. Absent such a demonstration, MISO’s proposal lacks sound analytical support.
For these reasons, much more time needs to be allotted to considering the issue of changing the allocation of capacity obligations to LSEs to ensure that the issue is very carefully considered, stakeholder views can be fully heard (e.g., via stakeholder presentations to the RASC such as that which was requested by the End-Use Customer Sector representative Jim Dauphinais at the August 22-23, 2023 RASC Meeting), and all necessary analysis can be performed (including, but not limited to, analysis of the potential impact of the proposal on each and every MISO LSE) to ensure any proposal ultimately filed by MISO at FERC is just and reasonable.
In conclusion, MISO’s proposal to change the allocation of capacity obligations to LSEs must be severed from the forthcoming November 2023 Direct LOL filing in order to provide sufficient time to consider the issues associated with this significant proposed change in wholesale cost of service and rate design practices with respect to capacity. Therefore, we once again call on MISO to:
Thank you for providing us an opportunity to provide the above comments. If it would be of help, we would be glad to discuss the above comments further with MISO and other stakeholders. If you have any questions regarding these comments, please do not hesitate to contact any of the following representatives:
Jim Dauphinais
Brubaker & Associates, Inc.
(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)
(636) 898-6725
Ali Al-Jabir
Brubaker & Associates, Inc.
(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)
(361) 994-1767
Ken Stark
McNees Wallace & Nurick LLC (for CMTC)
(717) 237-5378
Kavita Maini
KM Energy Consulting, LLC (Consultants to MIC)
(262) 646-3981
[1] ABATE, IIEC, LEUG, TIEC, CMTC and MIC are all MISO Members in the End-Use Customer Sector. NLCG is a non-MISO Member stakeholder whose members include large end-use customers within Indiana that are interruptible and/or have cogeneration facilities and that take service under NIPSCO Rate Schedule 831, which allows limited market purchases through Northern Indiana Public Service Company (NIPSCO).
[2] Comments of ABATE, IIEC, LEUG, TIEC, CMTC, MIC and NLCG (Eligible End-Use Customers) Regarding RASC: Accreditation Reform (RASC-2020-4, 2019-2) (20230711-12), July 28, 2023
[3] MISO Presentation: Market Redefinition: Accreditation Reform, RASC, August 22-23, 2023 (https://cdn.misoenergy.org/20230822-23%20RASC%20Item%2009bi%20Resource%20Accreditation%20Presentation%20(RASC-2020-4,%202019-2)629918.pdf) at Slides 2 and 9-16.
[4] Id. at Slide 2.
[5] Id. at Slide 13.
[6] See, e.g., Batavia, Naperville v. FERC, 672 F.2d 64, 80-81 (D.C. Cir. 1982) (explaining rate design principles behind peak demand allocation methods).
See word document.
Key Capture Energy (“KCE”) appreciates the opportunity to provide feedback on MISO’s capacity accreditation reform process. KCE is a developer, owner, and operator of large-scale stand-alone energy storage systems, with 624 megawatts (“MW”) of standalone energy storage projects in construction and operations and a development pipeline of over 8,000 MW of storage projects across the United States, including more than 1 GW in MISO.
KCE strongly supports adoption of two recommendations proposed by NextEra and Invenergy to ensure rational capacity accreditation outcomes for storage should a Direct Loss of Load (“DLOL”) methodology be adopted.
First, KCE supports the inclusion of more critical reliability hours per season in the DLOL calculation. This will mitigate year-to-year variability in resource accreditation and provide a more consistent investment price signal to dispatchable resources like energy storage. KCE conceptually supports the recommendation of including the top 65 hours as an appropriate starting point.
Second, KCE supports implementation of the “capacity equity” dispatch heuristic described in the NextEra/Invenergy presentation (see slide 12). This will help avoid erroneously low capacity accreditation values for energy limited – but dispatchable – resources like storage. Without a modified dispatch heuristic, the DLOL methodology will naturally skew toward low capacity values for storage because the state of charge will tend to be exhausted in the reliability model when LOL events occur. However, storage resources are still contributing to reliability by avoiding loss of load (“LOL”) in hours preceding a LOL event, and should receive higher accreditation accordingly. Therefore, it is critical to adopt the recommended “capacity equity” dispatch approach which will help address this flawed outcome. This approach makes the most sense because it captures the reliability contribution profile of storage when Expected Unserved Energy (“EUE”) occurs during net peak load, and net peak load is the time of day when maximum dispatchable capacity it needed.
KCE appreciates the opportunity to comment and is happy to discuss this topic further with MISO staff.
Comments from the MISO Cities and Communities Coalition Participants on the Resource Adequacy Subcommittee—Accreditation Reform
September 6, 2023
Submitted on behalf of the MISO Cities & Communities Coalition
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 accreditation reform proposal. MISOCCC is a coalition of communities 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.[1]
MISOCCC is concerned MISO’s resource accreditation proposal undervalues energy storage and renewable energy’s contributions to resource adequacy. This concern is based on challenges posed by the Direct-Loss of Load (DLOL) dispatch assumptions and reduced Planning Reserve Margin Requirement (PRMR), as presented by NextEra Energy and Invenergy in their DLOL Enhancements Proposal at the Aug. 23 Resource Adequacy Subcommittee meeting.
NextEra Energy and Invenergy’s presentation showed that assumptions on how energy storage behaves can have dramatic implications, not only on the way energy storage is accredited, but on the way other resource types are accredited. Additionally, their presentation showed the PRMR reduction raises equity and free ridership concerns for solar.
MISOCCC’s member communities are interested in the development of localized solar and energy storage resources as part of their clean energy goals and plans. The economic viability of these resources is directly impacted by the signals sent by MISO’s resource accreditation process. MISOCCC requests MISO further explore their proposal’s impact on energy storage and renewable resources through the stakeholder process.
Sincerely,
The MISO Cities and Communities Coalition
Kim Harvey
Director, Sustainability
City of Minneapolis, Minnesota
Jeremy Caron
Sustainability Program Manager
City of Des Moines, Iowa
Greg Nichols
Deputy Chief Resilience Officer, Office of Resilience & Sustainability
City of New Orleans, Louisiana
[1] For the purposes of coalition membership, the term “community” is defined as city governments, county governments, tribal nations, regional planning commissions, etc.
WEC Energy Group is supportive of MISO’s Reliability Imperative and the need to evolve the Resource Adequacy (RA) construct to account for the shift in resource mix and the associated risk when intermittent resources are not available. WEC Energy Group is concerned that several policy issues require additional investigation, simulation and discussion at the RASC prior to the filing of RA construct enhancements with the FERC:
Given the number and complexity of these issues, WEC Energy Group does not support a November filing. Our preference is to meaningfully work through these issues, avoid unintended consequences, and allow the recently adopted seasonal construct and performance-based accreditation to further mature.
WPPI remains generally open to the broad thrust of the accreditation reform that MISO is proposing. We do have a number of specific concerns, however, including the following.
MISO proposed at the August RASC meeting to change the way that PRMR is apportioned among LSEs. WPPI believes that this may well be appropriate in the long term, but that it is imprudent to plan to include such a proposal in MISO’s planned November accreditation filing. The discussion prompted by MISO’s presentation at the August 23 RASC meeting should be considered a very early step in moving towards a revised approach to allocating PRMR. MISO’s presentation raised a number of questions, including: complications introduced by combining simulation-based LOL hours with historical demand levels (something we don’t think MISO has previously proposed); whether MISO’s intent is to capture the range of demand deviation about a mean forecast or LSE-specific demand variation between the coincident peak hour and highest risk hours; how LMRs will be accounted for in historical demand measurement; and the possibility that this approach may, as MISO says, “require a change in the data LSEs need to submit.”
Particularly given that draft tariff changes have not been shared, these are all indications that the proposal is not near final form and that including it in a November filing would be premature. We strongly encourage MISO to defer this element of the RA construct to 2024 to allow these preparatory tasks to take place.
WPPI found Astrape’s Item 09.b.ii August 23 presentation compelling, particularly in its discussion of alternative heuristics for considering the effect of battery storage and other dispatchable energy-limited resources. Given the potential variation in accreditation values—even recognizing that Astrape’s example may not be representative of variation that could emerge in MISO—It appears appropriate for MISO and stakeholders to carefully assess which approach would be most appropriate to implement, and for MISO to share calculated accreditation results based on that approach prior to filing. We would ask MISO to share its response to each of the issues raised by Astrape at the October RASC meeting.
In its August 23 presentation, MISO proposed that DLOL accreditation values should be calculated using a straight average of availability values in Loss of Load hours, yet MISO says it is still considering whether to expand its consideration beyond Loss of Load hours to also encompass additional low-margin hours. We would suggest that it may be premature to finalize the averaging calculation before deciding upon which hours to include in the calculation.
Finally, we send separately a lightly marked-up version of the proposed Schedule 53 changes.
Mississippi Public Service Commission (MPSC) Response to RASC: Accreditation Reform (RASC-2020-4, 2019-2) (20230822-23)
In the August 22-23, 2023, meeting of the Resource Adequacy Subcommittee (RASC), MISO presented updates to the accreditation reform proposal including a Planning Reserve Margin Requirement (PRMR) strawman proposal and Schedule 53 Tariff redlines. Stakeholders were asked to provide feedback.
Comments are due by September 8.
Feedback
Generally, the Mississippi Public Service Commission (Commission) objects to MISO’s Direct Loss of Load (DLOL) proposal, particularly as it applies to solar generation.
1. MISO has not demonstrated that DLOL will more accurately quantify generation capacity resource adequacy value than does Unforced Capacity (UCAP) or Average Effective Load Carrying Capability (ELCC). Because MISO has decided to focus on limited and discreet hours of low margin, DLOL undervalues solar generation’s contribution to resource adequacy. As solar investment increases, the increase in solar generation during daylight hours will shift low margin hours to the evening when solar generation is unavailable. Yet, absent that solar generation, low margin hours would remain during daytime. MISO’s proposed DLOL accreditation is fundamentally flawed because it would not properly account for the resource adequacy value that solar provides during daylight hours.
The Invenergy/NextEra proposal to, among other things, expand the hours considered in accreditation is a step in the right direction and gets non-dispatchable resource accreditation closer to Schedule 53 accreditation of dispatchable resources.
MISO should further explore use of Average ELCC and the expanded hours DLOL proposal as methods that would more accurately determine solar contributions to Resource Adequacy (RA).
2. MISO’s proposal relies on a future scenario that underestimates the amount of storage needed to firm up renewable resources. As Dr. Patton explained in detail at the last LRTP Workshop, the future volume of renewables MISO assumes based on capacity expansion modeling using the EGEAS software is drastically overestimated. MISO should explain to stakeholders if and why Dr. Patton’s assertions are incorrect and whether improved modeling could address them.
3. MISO has not explained how dispatch assumptions for storage will be modeled (e.g., to maximize economic value to the owner, at 50% for 8 hours, at 100% for 4 hours). Without this explanation, accurate accreditation is not possible, and stakeholders will not understand what MISO is actually proposing. MISO has offered no explanation about battery operation.
4. MISO’s abbreviated description of it’s first-run of DLOL results does not explain the precipitous drop in capacity ratings from UCAP to DLOL; the descriptions are unintelligible. Such significant decreases expose LSEs to large resource adequacy shortfalls and associated penalties. MISO needs to explain and justify its approach and these results to stakeholders in detail.
AES Indiana (AESI) appreciates the opportunity to comment on the updated MISO accreditation reform proposal. These comments specifically cover the PRMR Strawman Proposal. AESI does not have any comments on the Schedule 53 redlines at this time.
Planning Reserve Margin Requirement (PRMR) Strawman Proposal
AESI would like to request MISO to explain why the Storage MWs from Spring to Fall goes from 28 MW to 54 MW, as noted on Slide 12. The impact does not appear to come from the accreditation change since on Slide 5 the seasonal capacity is 95% or 94% in each season.
Furthermore, AESI would like to continue to ask and urge MISO to discuss how the impact of future thermal resource retirements will impact storage and storage accreditation into the future.
Alliant Energy appreciates the opportunity to provide feedback on MISO’s proposed resource adequacy reforms. Overall, Alliant Energy continues to be supportive of MISO’s Reliability Imperative and the need to evolve MISO’s resource adequacy construct. As the resource mix changes and new challenges to operations continue maintaining reliability must be kept at the forefront. Alliant Energy does not believe; however, that MISO’s proposals are fully vetted or yet demonstrated to be a reasonable path forward. Further, the complexity of proposed changes by MISO creates the risk of unintended consequences and overall being ineffective and inefficient in meeting desired outcomes. MISO must better consider the needs of Load Serving Entities who perform resource planning and who, working with their regulators, control what resources are brought online. Alliant Energy asks MISO to engage more with stakeholders and take the time needed to ensure final proposals are done right.
MISO should be mindful of the significant airing of concerns brought up by stakeholders at the accreditation reform meeting. There was a large volume of comments as well as a breadth and depth of concerns on complexity, uncertainty, volatility, variability, etc. Alliant Energy agrees with many of the comments made and still has significant concerns about MISO’s evolving proposal, particularly in light of the looming near-term filing date. As a regulatory need, we are looking for constructs that are simple, predictable, and reproducible.
Accreditation volatility / variability concerns
One aspect that is of most concern is the potential volatility of the accreditation values. MISO must recognize that impacts to utilities could be significant, even if total values mitigate out at the footprint level. LSEs need stability in long-term planning assumptions to make sound long-term investment decisions. These investment decisions are generally between LSEs and their states – they are not made by MISO and they are not made by FERC. So MISO’s evaluation of a suitable construct must look to the LSE and state level.
To elaborate on the accreditation volatility concern, Alliant Energy points to the significant changes in accredited capacity shown in MISO’s UCAP vs DLOL table (slide 5). Further, the NextEra / Invenergy / Astrape SERVM analysis noted significant accreditation variability depending on methodology. This causes great concern about MISO’s proposal, and we are glad that MISO is considering an “expansion of hours to include hours within a certain margin threshold”. It would seem that a greater number of hours are needed to manage the accreditation variability / volatility issue.
We repeat our concern and request stated in the July comments:
We are aware that MidAmerican Energy has performed their own wind accreditation analysis which also challenges MISO’s assumptions. We have also performed this analysis and have significant concerns on wind accreditation volatility and the impacts on making long-term resource planning decisions.
PRMR and LSE obligation concerns
MISO provided interesting slides for its proposed PRMR / LSE obligation methodology, however Alliant Energy is not able to translate this into a meaningful representation of what our obligations may actually be in the near-term and long-term. We understand the high-level concepts, but MISO needs to provide significantly more information, examples, details, and numbers. Anything short of that does not accommodate a pathway for LSEs to understand how construct changes impact our long-term resource planning. For example, MISO could provide spreadsheets showing how individual LSE PRMRs would be calculated for the last three planning years.
Filing timeline concerns
Based on the current, premature level of development of MISO’s accreditation reform, and stakeholder outcry, Alliant Energy is surprised that MISO is continuing to signal a Q4 2023 FERC filing. A FERC filing should be delayed at least well into 2024 to allow adequate time for issue-vetting.
We are pleased that MISO remains committed to providing:
Due to the significant issues and concerns, MISO should also consider waiting for the next auction to clear, and then evaluate (shadow) its near-final reforms to understand impacts if implemented in the 2024-2025 Planning Year (as well as previous auctions)
Conclusion
Again, investment decisions are generally between LSEs and their states – they are not made by MISO and they are not made by FERC. So MISO’s evaluation of a suitable construct must look to the LSE and state level. We are concerned about a wide range of issues related to MISO’s proposal, such as: