In the November 7-8, 2023, meeting of the Resource Adequacy Subcommittee (RASC), MISO continued discussing accreditation reforms for Load Modifying Resources (LMRs). Stakeholders were invited to submit feedback on the proposed approach for near-term changes from the RASC presentation.
Feedback is due by November 28.
Alcoa Power Generating, Inc. (APGI)
Feedback on
“LMR Accreditation (RASC-2019-9) (20231107-08)”
November 28, 2023
During the November 8, 2023, Resource Adequacy Subcommittee (RASC) meeting, MISO requested feedback on their updated Load Modifying Resource (LMR) Accreditation proposal and certain design elements of the proposal.[1]
As a MISO Member, MISO Market Participant, and Load Serving Entity with LMRs registered and participating in MISO, Alcoa Power Generating Inc (APGI) has specific interests in the accreditation process for LMRs.
APGI offers the following feedback and suggestions:
APGI appreciates the opportunity to provide feedback on this issue.
If there are any questions or comments, please feel free to reach out to:
Steve Dowell
ESS LLC, Alcoa Power Generating Inc.
(812) 853-1135
DeWayne Todd
DDT LLC
(812) 573-8052
Alliant Energy is generally supportive of MISO’s current proposal. However, we are a bit apprehensive of the sliding accreditation scale for notification times on LMRs, and concerned about an overly strict two hour response time definition on tariff based programs.
WEC Energy Group submits this feedback in response to MISO’s proposed changes to LMR accreditation presented at the November 7 & 8 RASC meeting. WEC Energy Group supports enhancements to LMR accreditation to ensure their availability during emergencies to avoid the most critical level of emergency operations – firm load shed. However, time is needed to enhance the DSRI tool to accommodate LMR accreditation and to populate three years of historical LMR availability.
It is not clear from the presentation when the proposed LMR accreditation changes would occur. Comprehensive tracking of LMR availability requires DSRI tool improvements. Application of Schedule 53 accreditation to LMRs requires at least three years of detailed LMR availability during Tier 2 hours. If DRSI tool improvements are implemented late 2024 or early 2025, the LMR accreditation changes should occur in 2028. A 2028 implementation date aligns with the proposed transition period for DLOL accreditation. We support that alignment because in addition to providing three years of comprehensive LMR availability data, it also provides time to make retail tariff changes to incorporate the proposed “sliding scale” notification time. It also provides ample time to continue DSRI tool improvements to accommodate unique LMR programs.
We continue to have reservations regarding the EPNode mapping of LMRs that are not specific to a single customer at a single delivery point. While we agree that deploying LMRs based on EPNode location will improve the granularity of congestion relief, a single LMR program can span across a service territory with little or no ability to deploy that LMR on an EPNode basis. The mapping of LMRs needs to accommodate these types of programs.
Our experience with the use of an operational tool such as CROW for accreditation purposes does give us concern with the use of the DSRI tool for LMR accreditation. The DSRI tool is an operational tool and time is needed to ensure its proper functioning for accreditation purposes. This further supports our recommendation for a three-year transition to the new LMR accreditation. As an example, an additional line item such as “MW Deployed by MISO” may help in those situations where MISO selectively deploys LMRs on an EPNode basis. Operational experience will help to identify these types of enhancements.
MISO’s proposal for enhanced auditability of LMR data requires further refinement and a demonstration of why the existing audit and penalty provisions are insufficient. Requiring meter data for LMRs (whether assigned a Scheduling Instruction or not) when a Capacity Advisory is declared is burdensome and may not provide any useful information. For example, a customer participating in an LMR program may decide to cancel its afternoon shift if MISO issues a Capacity Advisory or initiates the Max Gen process. If that customer is not “dispatched”, its meter data for the day will show a shortfall in load reduction because it has unilaterally decided to self-schedule its load reduction. If the reason for this shortfall is unknown, it could appear – incorrectly – that the customer would not be able to provide its expected load reduction. Depending on DSRI enhancements, this load reduction could be reported within “Self-Scheduled by MP”. However, timing differences associated with updating the DSRI data table and MISO’s declaration(s) could exacerbate meter data and availability inaccuracies.
As an alternative to enhanced auditability (and the associated overhead), MISO and stakeholders should consider strengthening the LMR penalty provisions to encourage availability. The proposed application of Schedule 53 to LMRs (and associated DSRI improvements) may provide sufficient incentives to accurately report LMRs and negate the need for enhanced auditability.
LMR Accreditation Design Details Feedback:
When will the changes be implemented?
Why won't MISO accommodate the TO limitation as part of the DSRI?
Why would MISO reduce accreditation of a LMR during non event hours when accreditation is impacted during Tier 2 RA hours?
Why would MISO create an "unlevel" advantage between ARCs vs LSEs?
Advanced Energy Management Alliance
MISO Resource Adequacy Sub-Committee (RASC)
“LMR Accreditation (RASC-2019-9) (20231107-08)”
November 28, 2023
Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Resource Adequacy Sub-Committee (“RASC”) on the feedback request made by MISO at the November 10, 2023, meeting of the RASC.[2] AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy resources. AEMA members support the beneficial incorporation of distributed energy resources (“DER” or “DERs”), including advanced energy management solutions, into wholesale markets as a means to achieving electricity cost savings for consumers, contributing to system reliability, and ensuring balanced price formation. These comments represent the collective consensus of AEMA as an organization, although they do not necessarily represent the individual positions of the full diversity of AEMA member companies.
At the November 10th meeting of the RASC, MISO presented their proposal for near-term actions on Load Modifying Resource (LMR) Accreditation. MISO requested feedback on the proposed LMR accreditation reforms. AEMA offers the following comments:
AEMA appreciates MISO’s consideration of these comments as part of the examination of resource accreditation issues within MISO. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to discuss this with AEMA members.
Respectfully Submitted,
Katherine Hamilton
Executive Director, Advanced Energy Management Alliance
Katherine@aem-alliance.org
202-524-8832
or
DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052
[1] For additional information, see AEMA website: http://aem-alliance.org
American Municipal Power (AMP) appreciates the opportunity to provide feedback on the LMR accreditation near-term changes and offers the following comments.
As an initial matter, we would request clarification from MISO as to the scope of the proposed “near-term changes.” At the August RASC, MISO presented the concept of an LMR-accreditation sliding scale as part of a “Long-Term Strawman,” but at the November RASC MISO appeared to suggest that it would file sliding-scale LMR changes in the first quarter of 2024. Is this indeed correct and, if so, what effective date does MISO propose?
WPPI does not support the sliding-scale accreditation proposal at this time, and we request that MISO provide a justification for the specific accreditation reductions proposed. We note that expected increases in battery-storage resources may mitigate the need for LMRs to have short notification times, and we suggest that MISO account for this in assessing future LMR needs. We would also ask MISO to describe their use, if any of the provision in SO-P-EOP-00-002 that allows MISO operators can call on LMRs sufficiently in anticipation of a Max Gen Event Step 2a to allow them to come on line when needed.
WPPI has no concerns about the proposal to collect location information for LMRs.
We support MISO’s proposal to improve the DSRI interface. We stress the need to make that tool “smart” as part of this effort. A longstanding issue, which WPPI has repeatedly raised at user-group meetings at MISO, is the inability for the current DSRI tool screens to talk to each other. Specifically, we ask that the tool be made to function such that when MISO issues scheduling instructions based on reported LMR availability, and LMR MW deployed are reported to the DSRI, the tool should AUTOMATICALLY reflect the reported deployment and show available MW reduced by the amount of the deployment submission to MISO. We see this as the one process with a very large margin of error and potential for double-deployment of LMRs in the event that MISO issues a second set of scheduling instructions.
Finally, we offer a few comments on MISO’s discussion around auditability. MISO notes at slide 8 of the presentation that disqualification in the current and future planning years may result from unavailability. Where a resource is reporting tight-hour unavailability in DSRI, e.g., “as a result of maintenance requirements,” that unavailability will be reflected in future accreditation. Accordingly, in this case, there is no obvious rationale for MISO to consider further disqualification steps. Moreover, there may be legitimate circumstances in which LMRs fail to perform, such as when BTMG reported as available in DSRI fails to start when called because of an equipment failure. All generation is potentially subject to such occurrences and this would not typically be a basis for disqualification. We believe MISO’s response to LMR unavailability and MISO's criteria included in any investigation should recognize this, and that this should be reflected in the tariff—or at least the BPM—in more detail than the current language simply noting that MISO may implement disqualification if it deems doing so appropriate.
MPPA supports WPPI’s request for clarification on the scope of the proposed “LMR Accreditation Near-Term Changes” and feedback, especially opposing the sliding-scale accreditation proposal and needing to see analysis that supports it. MPPA has additional questions/concerns:
Feedback in response to November 7, 2023 RASC Item 11aii:
Demand Reduction volume will be required for each EP Node (Slide 4).
On slide 4, MISO introduces a new requirement for market participants to report demand reduction volume per each EP Node, whereas the earlier proposals were to only list the EP Nodes affected without requiring quantifiable MW at each EP Node. MISO stated during the meeting that this was needed for operators to know the distribution of the impact when it’s dispatched, even though the operators cannot dispatch LMR's at individual EP Nodes but will continue dispatching at the aggregated CP Node level. MISO also stated that the LMR performance will not be evaluated at the EP node level, but will remain evaluated at the aggregated CP Node level.
The new requirement to list demand reduction volume for each EP Node places an undue burden on market participants to perform hundreds of additional analyses in LMR aggregations to quantify the weighted impact of the LMR's capability across each affected EP Node. GRE also doesn't understand why MISO needs this information if they cannot dispatch each EP node independently. But most importantly, MISO has not demonstrated how this additional granularity of detail will be incorporated into a reliability coordinator's operator tools in an efficient way to allow the operators to make use of the data during Local and Transmission System Emergencies. Are there going to be new EMS models and tools built to simulate and show the operators the potential impacts of the distributed dispatch of the LMR’s on a Transmission System Emergency? MISO said EP Node data would not be part of the DSRI, which is the reliability operator's main toolset for LMR dispatching. So if the operators won't see EP node data in the DSRI, how would the EP Node knowledge be available to the operators for decision making?
Show me how you plan to build operating models which actually take advantage of this granularity of data. If no tools or operator plans exist, then EP node demand reduction volumes are not required and MISO needs to strike this requirement from the LMR accreditation reform. If MISO does complete the development and deployment of such tools to allow operators to actually take advantage of this detailed data, then I would be more sympathetic to the extraordinary large data influx that MISO is demanding. But this large LMR data injection has no value to MISO operators if there are no tools in place to process and digest the data efficiently during emergencies.
This echoes other stakeholders who made similar verbal requests of MISO to demonstrate how operators will actually make use of this data. Until MISO proves that systems are in place to make use of the data, GRE objects to this change and asks MISO to remove the requirement to report demand reduction volume for each EP Node.
DSRI Tool for Accreditation (Slide 5, 6 & 13):
Merits of MISO proposal:
The DSRI tool currently doesn't incentivize LMRs to make more MW available to MISO beyond their accredited MW seasonal value - if a local hot day occurs for a weather dependent LMR, there may be 12 MW available even though the LMR only was awarded 10 MW of Seasonal Accredited Capacity during MISO Seasonal Coin Peak Conditions. This new structure seems to introduce an efficient incentive to reward LMR's based on their physical capability, even if it's more than their cleared SAC. So if the 10 MW LMR actually can reduce 12 MW during an RA hour, that would likely pass forward to next year's accreditation, whereas if the MP truncated the MW offer at 10MW then the MP is knee-capping their own accreditation opportunity for the next year.
Inequity of LMR performance evaluation vs. SAC awarded from RA Hours:
Still, it seems like the MP shouldn't be held accountable for performance evaluation at the 12 MW value that is being offered during an emergency. The extra +2 MW beyond the SAC 10MW are voluntarily being offered to the emergency, because the LMR was only awarded 10MW of SAC value for ZRC's. GRE would like MISO to consider the performance evaluation criteria for such an event, where the LMR is voluntarily offering more MW to a dispatch event than the LMR was awarded at the time of registration. In the event the LMR was dispatched when it showed 12 MW was available to MISO, will it only be held accountable to deliver the 10MW of seasonal accredited capacity when evaluated for performance penalties? Or will the LMR be held accountable to deliver 12 MW of reductions, even though it's MECT SAC value was only 10 MW?
Handling of DSRI data for accreditation when LMR only partially clears PRA:
The DSRI tool doesn't incentivize LMRs to make more MW available to MISO beyond what's cleared in the planning resource auction. So if an LMR only partially clears the PRA, the DSRI will only show the % of SAC that cleared in the MW values listed as available to MISO, rather than the full amount of LMR capability. So if MISO uses DSRI data to inform MW accreditation during a planning year when the LMR didn't fully clear, it's going to under-count the MW available.
One possible solution to this would be to allow the "Reduced Load Availability" field to be used to show the un-cleared portion of the LMR in addition to any weather-dependent derates or other FSL-related derates. This would allow the accreditation arithmetic suggested on Slide 6 to capture the un-cleared volumes of MW that the LMR possesses (but which have no obligation to perform in the emergency). Then, those un-cleared MWs of availability would count towards future years' accreditation computations.
Highlighting [Total LMR] if not equal to seasonal accredited MW Value (new).
GRE takes issue with the tool change which will provide a visual indication to the DSRI operator that something is wrong if the Total LMR is not equal to the Seasonal Accredited MW Value. Seasonal accredited values are computed based on the LMR’s capability at the conditions of seasonal coincident peak conditions, which don’t happen every day for temperature sensitive DR. Having it highlighted gives them impression that something is wrong, but it isn’t. MISO assumes that MW's Available for MISO would be lowered when Reduced load Availability is non-zero, which presumes the weather-dependent load is experiencing mild weather conditions that provide less interruptible loads than during MISO Seasonal Coincident Peak Conditions. In that case, (MW Avail to MISO) + (Reduced load availability due to weather) = Total LMR, which is what MISO likely imagined and - under those conditions - the tool would not highlight the values.
But the issue comes when the LMR has more MW available to MISO than what was awarded by the MECT during Seasonal Coincident Peak Conditions. The Market Participant should be allowed to list those values greater than SAC in order to allow the RA Hours calculations to honor those days when temperatures are extreme and make the LMR have MW's available beyond only those calculated during MISO Seasonal Coin Peak Conditions.
DSRI and MECT areas requiring improvements:
During registration of LMR's, MISO staff flagged GRE's draft submissions as erroneous when we submitted 3 monthly availability numbers which were all lower than our seasonal accredited capacity. However, weather-dependent LMR's have load which is dependent on temperature conditions, and it shouldn't be a surprise that Seasonal Coincident Peak conditions tend to have higher average temperatures (and thus higher load available for demand reduction) than does any singular month in a given season. As an example, in summer the Seasonal Coincident Peak conditions capture the “best of the best” peak days sampled across June, July and August over a number of years, say a 5-year average. Yet, when evaluating average monthly availability, some historical Junes may be milder temperatures and drag down the average June month’s availability, and same can be said for July and August. Since the Summer Seasonal Coincident Peak has been known to occur and settle amongst all 3 months, when you take the best of the best peak days, you’re going to get a higher temperature/weather condition for computing accreditation than you would from just evaluating June alone, July alone, or August alone. This will still be true when we move to RA hours for a season, which again will pick the “best of the best” hours from a season, but the average monthly availability will surely be a lower number than the SAC values.
GRE requests that MISO eliminate the requirement that one or more of the season's monthly availability values registered in the MECT must be equal to the seasonal accredited value. Additionally, MISO should allow all months to be lower than seasonal accredited values if the conditions of that season warrant the separation given the weather-dependent nature of Demand Resources.
Sliding Scale Accreditation vs earlier access to LMR's (Slide 7).
MISO proposes a sliding scale to derate LMR's SAC values based on notification time. MISO has also stated in the August 2023 RASC that MISO plans to make changes to allow LMR's to be accessible prior to emergency conditions. Currently MISO operations cannot access LMRs without calling an EEA2.
For the long-lead time 6-hour LMRs, MISO proposed that accreditation rules would be modified to award these assets differently based on the speed of their startup notification time. GRE doesn't believe that a sliding accreditation scalar based on notification time would be necessary or warranted, if the higher notification time resources will subsequently be dispatched more often than the 2-hour "emergency" LMRs.
For example, longer lead time LMRs with a 6-hour notification may get dispatched more often at early stages of emergencies, like Max Gen Alerts, Warnings and Events at Step 1 level under reliability conditions which may not eventually elevate to the Step 2 level warranting 2-hour "Emergency" LMR’s. In that case, 6-hour LMR’s will get activated likely more often that 2-hour LMR’s. Being more frequently dispatched is already a dis-incentive to be a longer-lead time 6-hour LMR compared to a 2-hour LMR. If MISO also applies a capacity accreditation penalty to the 6-hour resource, that LMR is being penalized twice. MISO should take care to solve the reliability and operational problem by making changes to the operational rules (i.e. having easier access to LMR’s at earlier stages in the Capacity Advisory). But MISO should not solve operational challenges using the resource adequacy rules pertaining to planning resource auction capacity market methodologies to solve a reliability concern.
GRE objects to the sliding scale of accreditation based on notification time, knowing that MISO intends to make 6-hour and 4-hour LMR's more readily available in earlier stages of Capacity Advisories, which intrinsically is an implied penalty due to more frequently being dispatched.
WVPA's comments are included as an attachment.
The Missouri Joint Municipal Electric Utility Commission d/b/a Missouri Electric Commission supports the feedback filed by the Michigan Public Power Agency and WPPI Energy relating to LMR Accreditation Near-Term Changes (RASC-2019-9).
MidAmerican Energy appreciates the opportunity to provide feedback on LMR Accreditation Near-Term Changes (RASC-2019-9) (20231107-08).
MidAmerican has the following comments:
DTE Feedback
DTE appreciates the opportunity to provide feedback on MISO’s near-term Load Modifying Resource (LMR) accreditation changes. DTE agrees that MISO must take steps to improve the confidence in and useability of the LMR data provided to MISO.
Requiring EPNodes when registering LMRs
DTE understands that MISO operators need to have more locational information pertaining to LMRs so that localized system emergencies can be better managed, and that this is the driving factor behind requiring all EPNodes associated with an LMR to be entered at the time of registration. However, DTE has multiple LMR programs that are dispersed across the entirety of DTE’s service territory. Under the MISO proposal, DTE would need to associate all affected EP nodes with the appropriate LMR, which would take many hours to properly enter and validate (for example, DTE’s residential air conditioning demand response program would require entry of over 1,000 EPNodes). On an ongoing basis, tracking changes in demand response programs (i.e. customers entering and leaving) and keeping MISO up to date on LMRs covering wide geographical areas would require excessive effort to track associations with EPNodes. Due to this, DTE recommends MISO allow a CPNode to be substituted in place of EPNodes for LMRs similar to the one described above.
DSRI Updates and LMR Accreditation Based on RA Hours
DTE is in favor of MISO moving towards accrediting LMRs based on their performance during RA hours and the implementation of the sliding scale accreditation based on notification time. This will more closely align LMR accreditation with other resource types and will give a more accurate representation of the capacity MISO can count on from LMR resources. DTE also supports the proposed changes to the DSRI as long as MISO provides more detail on how each of the new fields should be used, including providing real world examples so that the new fields can be easily understood with context. To improve the DSRI more, DTE would like to see MISO update the interface so that users with Read Only access can view LMR data within in DSRI. Currently only users with Read/Write access can see the data. This makes it difficult for support staff to review entries in the DSRI and with MISO’s increased focus on availability data in the DSRI allowing support staff to be able to review the data would benefit all parties. Additionally, will MISO still allow for market participants to opt-out of the testing requirements when registering DRs with the potential for a higher penalty when doing so?
Enhance Auditability of LMR Availability Data
DTE agrees that MISO should be able to validate the availability of LMRs and the accuracy of offers in the DSRI, and that this will become more important as the MISO service territory shifts towards more intermittent generation and increased electrification. However, requiring MPs to submit meter data after every capacity advisory and within 60 days of an event will be a significant increase in both the number of meter data submissions that happen throughout the year, as well as the speed at which the data must be submitted. Current rules require that meter data be submitted after a Maximum Generation event where an LMR is given a scheduling instruction, and MPs have 103 days to submit the meter data. Additionally, given the nature of certain industrial LMRs, the meter data that must be collected is not always readily available. Some meters must be manually read, and the process can be quite cumbersome. Further, after all meter data is gathered, submission through the Demand Response Tool (DRT) is a very manual process (further opportunities to improve the DRT are given below). For these reasons, DTE recommends that MISO consider either giving MPs 103 days to submit meter data to MISO, or elevating the stage at which meter data is required from Capacity Advisory to Maximum Generation Event Step 1.
Demand Response Tool (DRT)
While not contemplated in the current proposal, DTE offers the following comments regarding the Demand Response Tool and the potential for improvement.
The current state of the MISO DRT lacks the capability for integration and automation. DRR enrollment applications cannot be exported for automated validation, resulting in a need to take screenshots or manually typing/copy-n-pasting DRT information by LBA for further validation. For example, DRR enrollment validation requires location addresses and IDs for meter data analysis and at its current state DRT does not have an API or even an export in user friendly format.
Another example of lack of API is submittal of meter data and further M&V process. With a proposed increase of LMR/DRR M&V frequency, the process of meter data upload and performance validation is expected to become burdensome. Also, lack of an API makes it difficult for LSE and MP to automate shadow settlement review process for any DRRs and validate corresponding charge type calculations.
In the DRR enrollment process, an LBA has a responsibility to provide EPNodes for each enrollment. if there are more than one EPNode, especially for programs that cover wide geographical areas, an import of a list of EPNodes would be very helpful, especially for DRRs with large area coverage.
MISO needs to add an API that would allow LBAs to automate processes of
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: LMR Accreditation Near-Term Changes (RASC-2019-9) (20231107-08)
November 28, 2023
ABATE, IIEC, LEUG, TIEC, CMTC and MIC, as representatives of the End-Use Customer (EUC) Sector, and NLCG appreciate this opportunity to provide comments to MISO.
During the November 7-8, 2023 meeting of the Resource Adequacy Subcommittee (RASC), MISO continued discussing accreditation reforms for Load Modifying Resources (LMRs) and invited stakeholders to submit feedback on the proposed approach for near-term changes from the RASC presentation. These comments respond to that invitation.
MISO’s latest iteration of its Near-Term Proposal for LMR capacity accreditation as presented at the MISO November 7-8, 2023 RASC Meeting is as follows:
MISO indicated it plans to file its proposal, once finalized, with FERC by the 2nd quarter of 2024, but has not yet determined a proposed planning year for implementation beyond that of 2025/2026 for EPNode identification.
As detailed below, ABATE, IIEC, LEUG, TIEC, CMTC, MIC and NLCG have a number of concerns with MISO’s latest iteration of its Near-Term LMR Accreditation Proposal. We look forward to working with MISO to address our concerns in such a manner that reasonably continues the availability of LMRs as an important resource during emergency and/or near-emergency conditions within the MISO footprint while at the same time addressing the MISO concerns that have triggered MISO to advance its proposal. We continue to strongly encourage MISO to reach out to our sector, as well as others that provide LMRs today, not just during MISO’s RASC meetings and through formal feedback requests, but also informally between RASC meetings as needed such that MISO can better understand the perspective of LMRs. Improved and more frequent dialog can help MISO arrive at solutions that are viable not only for MISO, but also for those who provide LMRs such that any changes that are pursued to address MISO’s concerns do not lead to a drop in LMR participation, but rather foster increased LMR participation.
EPNode Reporting
It is not clear why MISO seeks EPNode information. As we have stated in previous comments, collecting the CPNode for each LMR at the time of registration should provide sufficiently granular locational information for MISO Operations.[2] Each CPNode already has an EPNode mapping associated with it, allowing the locations to be modeled in MISO’s network topology. We believe this provides sufficient information for MISO to reasonably deploy LMRs within the bounds of most transmission constraints, particularly given that MISO DRRs are only required to identify their CPNode, not their EPNode, and that CPNode can be a Load Zone CPNode. If the CPNode level of granularity is operationally sufficient for DRRs, it should be operationally sufficient for LMRs as well.
Furthermore, we continue to be concerned that MISO requiring EPNode information may unduly interfere with LMR aggregation. While MISO has indicated it would allow a single aggregated LMR to report several EPNodes, it appears MISO is requesting that the demand reduction at each EPNode be provided for the LMR. If this is a one-time request at the time of registration, this is likely manageable. However, if MISO intends to issue Scheduling Instructions to LMRs broken out by specific EPNode, this would be highly problematic. In our experience, aggregated LMRs are typically registered based on the expected overall performance of the aggregated LMR, not the specific performance of each individual load that is aggregated within that LMR.
MISO should only require LMRs to identify their CPNode at the time of registration similar to the practice with DRRs or, in the alternative, MISO should at least clarify that Scheduling Instructions issued to LMRs with multiple EPNodes will not be subject to EPNode specific performance requirements.
Additional MISO DSRI Fields
We appreciate MISO’s effort, through its proposed addition of the “Reduced Load Availability” field to the MISO DSRI, to address our previously expressed concern with respect to properly determining the historical availability of LMR Demand Resources using the Firm Service Level option when determining their capacity accreditation.[3] As currently proposed by MISO, it preliminarily appears the field will properly credit LMR Demand Resources using the Firm Service Level option (as well as LMR Demand Resources that are using Direct Load Control or are Weather Sensitive) for the portion of their non-firm demand that is already forecasted to be reduced. As we have indicated in past comments, LMR Demand Resources that use the Firm Service Level option have committed to remove all of their non-firm demand (i.e., all of their demand in excess of their specified firm service level) when called upon during Maximum Generation Events to do so at Step 2a or higher.[4] This commitment allows MISO to avoid carrying capacity to serve that non-firm demand. Furthermore, that commitment to remove all non-firm load allows that avoidance of capacity regardless of whether it is accomplished due to: (i) the non-firm load already being down or offline, (ii) the non-firm load already being curtailed through self-scheduling, or (iii) the non-firm load being available to MISO to be removed to the extent it is not already removed.
While MISO’s proposed addition of a “Reduced Load Availability” field to the MISO DSRI is helpful and appreciated, we do have the following concerns with respect to the remainder of MISO’s proposal with respect to the MISO DSRI and MISO’s proposed use of that information for the capacity accreditation of LMRs:
Accreditation Scaling Based on Required Notification Time
In our September 14, 2023 comments to MISO, we indicated that we are open to further discussing the potential use of a sliding scale for capacity accreditation for Non-Emergency LMRs based on notification time under MISO’s long-term LMR capacity accreditation proposal, provided it is fully supported by loss of load probability analysis that has been reasonably performed.[6] However, MISO has now proposed to accelerate pursuit of its sliding scale proposal for capacity accreditation based on required notification time by now including it in its near-term, rather than long-term, LMR capacity accreditation proposal. Furthermore, MISO has provided no analysis to support its proposed sliding scale percentages for capacity accreditation based on required notification time.
MISO’s proposed use of a sliding scale for capacity accreditation for Non-Emergency LMRs based on required notification time should not be part of MISO’s proposed near-term LMR Accreditation proposal that it intends to file with FERC during the 2nd quarter of 2024. Consideration of the sliding scale proposal should instead remain part of MISO’s long-term LMR accreditation discussions. Furthermore, MISO needs to fully support any such sliding scale proposal with a loss of load probability analysis that has been reasonably performed.
Enhanced LMR Auditing
The extent and frequency of MISO’s proposed additional documentation and meter data requirements for end use customer load associated with LMRs, including LMRs that have not received Scheduling Instructions, is not clear from its proposal. Depending on how these requirements are implemented, this proposal could be extremely burdensome to LMRs and have a very chilling impact on their market participation by dramatically increasing the bureaucracy associated with that participation. The enhanced LMR auditing proposal should not be further pursued prior to: (i) MISO more clearly defining its specific concerns, (ii) MISO presenting evidence supporting its concerns, and (iii) MISO ensuring the scope of what it specifically proposes to address its concerns is no further reaching than it needs to be. We conceptually support reforms that tie the capacity accreditation of LMRs to their availability during Maximum Generation Events and provide MISO a reasonable ability to verify that availability. However, such reforms need to be balanced with the administrative burden that would be imposed by them. In particular, it would be counterproductive to drive end use customers that currently participate as an LMR and have a good availability during Maximum Generation Events from such LMR participation by imposing unnecessarily burdensome audit requirements on them.
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] End-Use Customer Sector Comments “RASC: LMR Accreditation Feedback (RASC-2019-2 2020-4) (20220713), August 3, 2022 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/rasc-lmr-non-thermal-accreditation-feedback-rasc-2019-2-2020-4-20220713/#4) at page 7; End-Use Customer Sector Comments “RASC: Non-Thermal Accreditation (RASC-2019-2 2020-4) (20220824), September 7, 2022 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/rasc-non-thermal-accreditation-rasc-2019-2-2020-4-20220824/#12) at page 3; End-Use Customer Sector Comments “RASC: LMR Accreditation Reforms (RASC-2020-4 2019-2) (20221012), October 27, 2022 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/rasc-lmr-accreditation-reforms-rasc-2020-4-rasc-2019-2-20221012/#5) at pages 2 and 7; and End-Use Customer Sector Comments “RASC: LMR Accreditation (RASC-2019-9) (20230822-23), September 14, 2023 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2023/rasc-lmr-accreditation-rasc-2019-9-20230822-23/#11) at page 3.
[3] End-Use Customer Sector Presentation “Load Modifying Resource Demand Resources Using the Firm Service Level Option, MISO RASC, January 17, 2023
(https://cdn.misoenergy.org/20230117-18%20RASC%20Item%2011%20LMR%20DRs%20Using%20the%20Firm%20Service%20Level%20Option_End%20Use%20Sector627552.pdf) and End-Use Customer Sector Comments “RASC: LMR Accreditation (RASC-2019-9) (20230822-23), September 14, 2023 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2023/rasc-lmr-accreditation-rasc-2019-9-20230822-23/#11) at page 2.
[4] Id.
[5] End-Use Customer Sector Comments “RASC: LMR Accreditation Feedback (RASC-2019-2 2020-4) (20220713), August 3, 2022 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/rasc-lmr-non-thermal-accreditation-feedback-rasc-2019-2-2020-4-20220713/#4) at page 6; End-Use Customer Sector Comments “RASC: Non-Thermal Accreditation (RASC-2019-2 2020-4) (20220824), September 7, 2023 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/rasc-non-thermal-accreditation-rasc-2019-2-2020-4-20220824/#12) at page 4; and End-Use Customer Sector Comments “RASC: LMR Accreditation Reforms (RASC-2020-4 2019-2) (20221012), October 27, 2022 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/rasc-lmr-accreditation-reforms-rasc-2020-4-rasc-2019-2-20221012/#5) at page 3.
[6] End-Use Customer Sector Comments “RASC: LMR Accreditation (RASC-2019-9) (20230822-23), September 14, 2023 (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2023/rasc-lmr-accreditation-rasc-2019-9-20230822-23/#11) at page 4.
Feedback by Public Service Commission of Wisconsin (PSCW) Office of Regional Markets (ORM) Staff to MISO on near-term LMR changes
At a high level, with these near-term changes, and looking ahead to any long-term changes MISO may propose, we request that MISO avoid changes that make LMR participation cost prohibitive and cumbersome. Given interconnection queue backlogs and increased demand, it seems that procedures that reduce of the burden of LMR participation would be preferable.
Additionally, we have the following questions and concerns:
1) Could MISO clarify if the reduction in accreditation for LMR resources based on notification time is in lieu of MISO’s plan to have two separate categories for LMRs (emergency and non-emergency)?
2) We encourage MISO to explore ways to more effectively schedule longer lead time emergency LMRs rather than reduce the accreditation of those resources based on notification time. It is not clear what reducing accreditation for longer lead time LMRs will achieve if those LMRs are just as likely to fulfill their obligations.
3) We would appreciate MISO sharing more about how the categories for the sliding scale LMR notification times were selected. Specifically, were these categories based on operational considerations? We would also appreciate MISO sharing what proportion of current LMRs in MISO would fit into each category, and how the reduction in accreditation based on notification times was determined.
Duke Feedback to MISO’s LMR Accreditation Proposal (RASC-2019-9) (20231107-08)
General Feedback on Accreditation Revisions and Overall Process
Duke Energy Indiana (DEI) is very appreciative of most revisions made in MISO’s proposal and it appears much of the feedback provided during the last RASC has been considered and reflected in recent changes to the proposal. DEI also believes additional, dedicated conversation on LMRs at a deeper level would greatly benefit the continued development of the LMR proposal, particularly as it applies to the “longer term” revisions impacting LMR accreditation. This viewpoint (of a desire for a dedicated workshop or similar to discuss important nuances of LMRs at a deeper technical level) was shared by other stakeholders during the RASC and DEI would encourage MISO consider supporting such a session to gather productive feedback and welcome direct participation in such a discussion.
DSRI Tool Updates and LMR Accreditation Based Thereon
DEI appreciates and supports the updates to DSRI as detailed on slides 5 and 6 of the November 8th RASC presentation on LMR accreditation reforms. However, DEI has some concern – expressed verbally during the RASC meeting – that accreditation based on self-reported availability may leave unaddressed a serious risk of improper reporting by Market Participants (MPs) without MISO or other third-party auditing. This feedback should not be misconstrued as a desire for increased oversight or auditing per se, but rather that self-reported availability may not result in the outcome MISO desires. Surely, a review of hourly load data would make clear whether a particular LMR was truly experiencing an “Outage” or instead experiencing “Reduced Load”. DEI simply wants to provide feedback that given “Outage” values will unfavorably impact LMR accreditation in the next year and all values are self-reported by MPs, there may be little motivation on the part of MPs to consistently report values in a compliant manner and some level of checks and balances may be needed to address this potentially meaningful gap in LMR accreditation reform.
Direct MISO Dispatch of LMRs
DEI previously provided feedback after the August 22 RASC that having MISO self-dispatch individual LMRs may greatly assist in the overall process, particularly given the proposed move to shorter notification times and a greater number of registered LMRs. In a review of the MISO response to the August 22 feedback request, it does not appear this topic was addressed. DEI would reaffirm that such a change, while admittedly adding complexity to MISO systems and procedures, would provide significant benefits in terms of successfully executing load curtailment from LMRs during an actual event warranting LMR use and may warrant consideration for the long term proposal for LMR reform. Currently, this proposal largely complicates the management and dispatch of LMRs for the Market Participants (MPs) managing direct oversight of these resources. DEI would note such an approach largely results in either considerable timing being required on the part of the MP making decisions as to which MPs to dispatch and/or MPs deciding to call upon all (100%) of the LMRs available no matter how small of a fraction MISO may have called for during an event. Such an approach likely results in delayed response time and may reduce the amount of MWs available later in a curtailment event as all resources would have already been called upon be each MPs.
LMR Accreditation “Capping” and Testing Methodology
During the RASC meeting, the topic of “capping” LMR accreditation as noted on slide 6 of the presentation materials was discussed. MISO noted they would be proposing changes to the LMR testing methodology, but that ultimately MISO desired to “cap” LMR accreditation at the capability / capacity level borne out or otherwise supported through test data. While DEI heartily supports updates both to LMR M&V Methodologies (Tariff Attachment TT) and LMR testing requirements (as outlined in Tariff Module E-1 and BPM-11), DEI seeks to ensure that either these aforementioned revisions are addressed prior to “capping” being implemented as part of this proposal, or that any such capping be delayed until such time as testing requirements and M&V methodologies can be more fully and formally addressed.
Wolverine continues to support MISO’s efforts to put all resources on a level playing field that directly ties capacity accreditation with resource availability.
As it pertains to MISO’s November 8, 2023 proposal, Wolverine supports most of MISO’s LMR accreditation proposal for the near-term solution, including the requirements for more data collection and having access to real-time data. That said, there are items that Wolverine does not support or would like further improvements.
Oppose
Wolverine opposes the sliding scale accreditation based on notification times. Including this requirement continues to treat LMRs separately and distinctly from all other resources – no other resources have a sliding scale accreditation.
Further Improvements
MISO’s proposal to expand the functionality of the DSRI tool is a step in the right direction – more data and awareness provides MISO the necessary intel to reliability operate the grid with more certainty. That said, relying on the DSRI will continue to treat LMRs differently than all other resources. In particular,
As MISO continues efforts on a long-term solution, Wolverine supports efforts to evolve and further align LMR accreditation methodology comparably to all other resources. These efforts will likely result in a fair and equitable accreditation and compensation for the same product as well as improve the certainty to resource planning processes to the benefit of reliability.
CPower Comments to MISO’s November 8, 2023 RASC Feedback Request on Accreditation Reforms for Load Modifying Resources
November 28, 2023
During the November 8, 2023 RASC meeting, MISO presented an updated proposal for accreditation reforms for Load Modifying Resources (“LMR”). Enerwise Global Technologies, LLC d/b/a CPower (“CPower”) appreciates the revisions to the proposal reflective of stakeholder feedback following the August RASC meeting, as well as the opportunity to provide feedback to MISO on its revised proposal. CPower thanks MISO staff for their review and consideration of the feedback below. Should you have any questions, please do not hesitate to contact Peter Dotson-Westphalen.
Near-Term Proposal
CPower remains supportive of MISO’s plan to obtain additional information from Market Participants (“MP”) during the registration process to inform its operations staff of the location of the individual accounts included in each LMR registration to utilize LMRs more efficiently and effectively to avoid creating or exacerbating any transmission constraints within a Load Zone or LBA. However, CPower does not support MISO’s revised proposal to require the MP registering the LMR to provide the EPNode for each account within an LMR. CPower’s understanding is that MISO will not be able to provide this information to the MP. Instead, the LBA and/or LSE will need to provide this information to ARCs in advance of submitting the LMR registration, and it is also our understanding that LBAs/LSEs may not readily be able to provide this information for hundreds, let alone thousands, of customer accounts. Implementing this requirement will create a new administrative burden on both the MP registering the LMR, as well as on the LBA/LSE that will need to provide this information to the MP.
While CPower supports MISO accepting EPNode information if it can be provided (for example, some MPs that are themselves LBAs or LSEs may be able to provide this information more easily than ARCs), requiring this effective for the 2025/26 Planning Year may create a barrier for ARCs, placing them at a competitive disadvantage to other MPs. Until LBAs/LSEs have systems and processes in place to easily provide this information to support the locational requirement, CPower strongly recommends MISO not require EPNodes and instead continue to accept zip code information for the accounts to be registered as MISO proposed in its presentation on August 23, 2023.
CPower does not oppose providing a breakdown during the LMR registration to provide the total amount of load reduction expected at each sub-location (either by zip code or EPNode).
Long-Term Proposal
Future Accreditation of LMRs
MISO’s revised proposal for future accreditation of LMRs plans to utilize availability as indicated in the DSRI during Tier 2 RA Hours (per Schedule 53), including Max Gen and the tightest margin hours over the past three years to determine the ZRCs accredited to each LMR.
CPower appreciates the thought that MISO has put into the proposal to attempt to align its LMR accreditation proposal to be in line with other resource types. The longer look back period may make sense for other types of resources, but LMRs can be different. An area for consideration that does not appear to have been addressed is how the proposed methodology will work with LMRs that have changing accounts comprising them year to year.
Basing accreditation upon historical availability using MISO’s proposed methodology may not reflect the availability of individual customers participating as part of an LMR, and a customer moving from one MP to another could result in it being inadvertently positively or negatively impacted with the amount of capacity the LMR to which it is registered may be accredited. This may not be a significant issue for certain types of customer, such as residential air conditioning programs, where the method by which load reduction is achieved may be the same with customers of similar sizes and contributions to the registered quantity for the LMR. In cases where commercial and industrial customers are participating, there may potentially be much larger swings in availability based upon the business’ operations. MPs representing participating customers may then need to weigh creating a new LMR registration that would receive the class average accreditation to avoid negatively impacting the accreditation amount.
CPower recommends further discussion of this subject during the next RASC meeting during which LMR accreditation is discussed, and would be willing to discuss this further in advance with MISO staff.
Notification Time Impacts to Accreditation
CPower understands the desire to accredit LMRs with shorter notification lead times higher than those with longer lead times. We would like to better understand the analysis that resulted in the sliding scale values contained in the proposal. To the extent that other resource types may be subject to a sliding scale for accreditation based upon how much lead time is required for those resources to respond, CPower recommends that the scaling factors be in line with those resources with similar notification/response/start-up times.
Enhanced Auditability of LMRs
MISO proposes to expand its audit capability of LMRs by requiring MPs representing LMRs to provide documentation and meter data for the end use accounts comprising the LMRs within 60 days following MISO’s declaration of a Capacity Advisory or higher system notification. CPower understands MISO’s desire to obtain additional insight to validate that the availability reported in the DSRI was accurately reflecting the LMR’s actual availability.
CPower cautions that this may create additional administrative burdens on all parties involved, including for MISO staff. Before MISO moves forward with this portion of the proposal, we would like to better understand what MISO intends to require for additional documentation to be provided in addition to the meter data. CPower also would like to better understand how this additional information will be used and how MISO intends to align penalty provisions with existing rules, and how it may impact future accreditation.
Conclusion
CPower appreciates the opportunity to comment and looks forward to further discussion of this topic in the stakeholder process.
Respectfully,
Peter Dotson-Westphalen
Sr. Director, Regulatory & Government Affairs
CPower
Peter.D.Westphalen@CPowerEnergyManagement.com
781-214-7523
The OMS Resources Work Group (RWG) and Distributed Energy Resources Work Group (DERWG) provide this feedback to MISO on its proposed near-term changes to LMR accreditation. This feedback is from OMS work groups and does not represent a position of the OMS Board of Directors.
Locational Requirements
The RWG and DERWG support MISO’s proposal to require EPNodes instead of zip codes when registering an LMR. The work groups agree that identifying LMRs by EPNodes will support system reliability by providing more accurate LMR locational information during emergencies and will better inform congestion management decisions. However, this requirement will likely increase the workload of EDCs to identify those nodes for aggregators. This trend of increasing work for EDCs will continue under Order No. 2222 as well, likely requiring them to hire more staff and/or further automate their processes.
The work groups recognize that the data asymmetries presented by this requirement may introduce a barrier to market entry since the majority of LMRs registered with MISO are part of an EDC program and the EDC is the entity with the EPNode data.
Automation
The RWG and DERWG encourage MISO and stakeholders to explore opportunities to automate LMR registration processes to handle increased levels of demand response, which may be applicable to DERs as well. The work groups note that automation of MISO and EDC processes will be essential to fully realize the benefits of DERs and ensure security of customer information.
Availability
The RWG and DERWG emphasize that updates to MISO’s Demand-Side Resource Interface (DSRI) tool are overdue. If adequately updated, however, the DSRI tool could be utilized to track and provide availability-based data for purposes of LMR accreditation.
Still, LMR owners should be updating the DSRI tool regardless of changes to LMR accreditation. Not accurately reflecting LMR availability was a primary factor in the substantial underperformance issues experienced in previous events and needs to be corrected.
Notification
MISO’s proposed adjustments to accreditation based on notification time may be reasonable. The RWG and DERWG encourage MISO to support the values in the sliding scale below with data linked to the actual operational reliability they provide. Furthermore, it would be helpful to evaluate the notice requirements and relative performance on a seasonal basis. This could be accomplished by conducting a historical analysis of the number of emergency situations that were knowable in advance within the given notification times below. LMR accreditation should be directly linked to the value that each block of notification times provides.
The work groups believe MISO’s proposed sliding scale based on notification time may be reasonable but needs to be supported by data as described above:
The work groups recognize that longer-lead time LMRs may face more physical or economic limitations than short-lead time resources and that decreasing their accreditation may render them uneconomic and therefore, less willing to offer into the PRA as an LMR product.
Auditability of Data on LMR Availability
The OMS RWG and DERWG support enhanced verification to ensure LMRs are documenting their availability appropriately. However, it may be overly burdensome to require LMRs to obtain meter data for each Capacity Advisory that MISO declares. This scenario would likely create additional work each year as those events occur relatively often and seem to be increasing.
The work groups request that MISO provide data on the number of Capacity Advisories that have been called in recent years. This data should also include a breakdown of the times where MISO called for a higher level in the Emergency Procedures, such as Max Gen Alert and Max Gen Warning. The data might show that a higher level in the Emergency Procedures (such as a Max Gen Alert, Warning, etc.) would be more appropriate and achieve the desired result.
Voltus Comments to RASC on LMR Accreditation Near-Term Changes (RASC-2019-9) (20231107-08)
November 28, 2023
Voltus submits these comments on proposed changes to LMR accreditation as the first and largest aggregator of retail customers (ARC) representing residential, commercial, and industrial demand response megawatts as LMRs in the MISO market.
Locational Information
At the end of 2022, MISO began requiring ARCs to provide EP Nodes for each unique Location enrolling as a DRR Type 1 resource. That process has proved to be very cumbersome, time consuming, and prone to error, because EP Node information is not public, so ARCs are entirely reliant on the responsiveness of LBAs to provide values that are both timely and accurate. For DRR Type 1 resources, this is a relatively minor hindrance due to the small number of resources. If ARCs were required to provide EP Node data for LMRs, however, it would be very detrimental to ARCs’ ability to enroll resources, especially aggregations of smaller resources such as residential smart thermostats of which there can be thousands per aggregation.
Until ARCs have first-hand access to EP Node data, LBAs rather than ARCs should be responsible for providing EP Node information directly to MISO, as LBAs are the sole market participants with direct access to that data. The identification of EP Node data could be added to the scope of the existing 10-day review process, wherein LBAs (along with LSEs and RERRAs) can review LMR enrollment data. MISO would need to identify a fallback method of identifying EP Nodes in cases where LBAs are not responsive within the 10 day window.
DSRI Tracking of LMR Availability
Voltus supports the proposal to increase the granularity of availability data tracked in the DSRI, with two caveats of note: (1) continued support of the API to make bulk updates will be vital to the ability of market participants to maintain accurate data, and (2) in the long-run, if not immediately, MISO should auto-populate the DSRI with the relevant DRR offer values from the MUI and EDR offer values from the EDR Offer tool. Alternatively, for EDRs specifically, once appropriate enhancements to the DSRI have been made, MISO could deprecate the EDR Offer Tool and make the DSRI the source of truth for EDR offers. This option would have the added benefit of providing MISO operators with hourly visibility into EDR availability.
DSRI Accreditation
Voltus requests clarification from MISO on the timing of implementing availability-based accreditation. MISO’s proposal is, seemingly, to use historical availability in Tier 2 hours of the past three years. This would mean that availability-based accreditation from the DSRI would not be possible until three years of historical data is available.
Sliding Accreditation Scale
Voltus requests clarification from MISO on the logic behind the sliding scale accreditation values shared by MISO. What logic leads MISO to believe that a 2 hour increase in notification time from a 2 hour baseline translates into a 30% reduction in the capacity value provided by a resource, while a 4 hour increase translates into a 50% reduction in capacity value? Are these values based on modeling, or on precedent in other markets or programs?
Enhanced Auditability of LMRs
MISO is proposing the MPs submit significant volumes of data every time a Capacity Advisory is declared in the MISO footprint and that these data must be submitted within 60 days of the declaration. Voltus supports enhancement of MISO’s ability to audit historical availability to ensure market participants are accurately inputting availability to the DSRI. However, given the administrative burden of gathering, verifying, and submitting data to MISO, Voltus is skeptical that these data should be provided for every Capacity Advisory. Rather, MISO should only request these data when it has decided to conduct an audit of the reported availability by the MP. The risk of random audits, on top of our existing Tariff compliance obligation, will be sufficient incentive for MPs to provide accurate availability data.
Voltus does not support accelerating the timeline of data submissions for audit purposes to be earlier than the data submission deadline for LMR dispatch performance measurement and verification, for which MPs have 103 days to provide interval data to MISO.
Open Questions Not Yet Addressed
Voltus requests that MISO clarify its proposal regarding how availability-based accreditation values will be applied. Are values calculated and applied across the entire MISO LMR portfolio or on a more granular basis - e.g. by LBA territory, by market participant, by resource, or by individual locations within a particular resource? Voltus proposes that these values be calculated and applied at the most granular level possible.
Respectfully submitted,
Emily Orvis
Vice President of Energy Markets
Voltus, Inc.
emily@voltus.co
to: | MISO Resource ADEQUACY Subcommittee |
from: | The Entergy Operating Companies |
subject: | LMR Accreditation |
date: | November 28, 2023 |
The following feedback is offered by The Entergy Operating Companies ("EOCs or Entergy”) in response to the request made during the November 2023 Resource Adequacy Subcommittee for stakeholder comments on MISO’s revised proposal for changes to market rules regarding LMR participation and accreditation.
First, the EOCs wish to convey support for the DSRI changes which we appreciate MISO changing in light of Stakeholder feedback to focus on EP Node and not Zip Code.
However more crucially, as explained more fully below, the EOCs still have significant concerns about the proposed changes to the LMR accreditation rules. These changes, if implemented as currently proposed, still carry significant risk of driving LMRs out of the market over a short period of time and creating a capacity shortfall. Moreover, MISO has still not explained why the proposed changes, particularly the accreditation change MISO is proposing, are necessary or beneficial to the market. The EOCs urge MISO to reconsider its proposal in light of the comments that follow.
We would appreciate MISO clarifying the timeline for the accreditation changes. It seems the short- and long-term proposals from the September meeting have collapsed into one timeline. The condensing of the timeline for the accreditation changes presents a major hurdle for the EOCs as this is too short of a timeline to make any changes to our retail tariffs.
Entergy expressed significant concerns in our September feedback about the long-term proposal of accreditation changes. This new proposal is much better, but we reiterate some of our previous concerns and highlight other new issues with the new proposal:
The EOCs would propose the following (high level) alternative LMR accreditation change:
We look forward to working with MISO and other Stakeholders on this proposal as improving reliability of the system, and increasing participation of demand response and DERs remains at the forefront of the EOCs initiatives.
Xcel Energy appreciates the opportunity to provide feedback on MISO's proposals for LMR accreditation, as presented at the November RASC.
Since changes are needed to the DSRI Tool to capture the three years of historical data in the format that is needed to accredit LMRs and LSEs need time to adjust their retail tariffs and their processes, MISO should use the current LMR capacity accreditation methodology through the same three-year transition identified for the DLOL. This would also allow time for improvements to the MECT for LMR registration.
We support the inclusion of EPNodes within the registration in the near-term, but support stakeholder's request for more information as to how MISO Operations will use the data. MISO cannot require LMR group registration split by EPNode until significant improvements have been made to the MECT for LMR registration. It is currently a manual, inefficient process to register LMRs; requiring current groups to be split into registrations by location will increase the number of registered groups significantly and make the already inefficient registration process inadequate.
Regarding MISO's proposal for a sliding capacity accreditation scale, we support stakeholder's recommendations to develop the values on the scale using SERVM analysis.
MISO proposed to require documentation and/or meter data during periods when a Capacity Advisory or higher is declared, regardless of Scheduling Instructions. Please provide more information on how the penalty would be calculated and how future capacity accreditation could be impacted.
Comments on MISO Proposed Approach for Near-Term Changes to LMR Accreditation (RASC-2019-9)
Submitted by Thomas Siegrist, SMXB Consulting Engineer
As part of the November 8, 2023 MISO RASC meeting, MISO requested feedback on its proposed approach for near-term changes to its LMR accreditation. Our firm works with several industrial customers in the MISO footprint that act as LMRs. Based on our experience, we offer the following initial comments and concerns.
First, MISO’s Demand Side Resource Interface (DSRI) Tool should not be used to track LMR availability (for capacity accreditation purposes or otherwise) for LMRs that drop down to a specific Firm Service Level (FSL). FSL LMRs are often industrial customers that utilize batch processes, whose load cannot be forecasted with precision on an hour-by-hour basis.
As stated in prior feedback, many LMRs take interruptible service that is not based on a specified amount of load reduction, but instead is predicated upon the LMR load dropping down to a specific FSL, regardless of their actual load level when notified to reduce load. If the LMR drops down to its FSL, and stays there for the requested duration, then the LMR should be regarded as 100% available and compliant, and should receive full accreditation. The DSRI Tool is simply not a reliable or accurate mechanism by which to monitor the MW available to MISO from FSL LMRs, nor to determine their capacity accreditation.
If, despite these considerations, MISO is determined to further explore the potential use of the DSRI Tool for operational purposes related to these FSL LMRs, then at the outset, further discussion of MISO’s proposed additional fields for the DSRI Tool is needed. For example, as currently described by MISO, the existing and new fields are not clear as to whether they would accurately reflect an LMR’s potential hourly load, particularly LMR batch load that could come back on the system in any given hour.[1] At a minimum, an example of the DSRI Tool for an FSL LMR is needed, including narrative descriptions of each applicable field in the DSRI tool.
Second, with respect to LMR accreditation, MISO’s 11/8/23 presentation includes a convoluted process for the calculation of “accredited MWs.” Capacity accreditation for FSL LMRs can and should be simplified and take place outside of the DSRI Tool. “Available” MW for potential accreditation for FSL LMRs can be based on the following calculation: (Contract Demand or Peak Load) minus (Firm Service Level).[2] The FSL LMR load should be measured during curtailment against its FSL. That is all that is required and, without modification, the DSRI Tool will not be useful in making this determination.
Lastly, MISO proposes the following sliding scale to reduce accredited values based on notification time that would be applied in MISO’s MECT to each LMR prior to the PRA:
0 to 2 hours = 100%
2 to 4 hours = 70%
4 to 6 hours = 50%
MISO’s proposed sliding scale for LMRs is unnecessary and not justified at this time. MISO moved to the current 6-hour notice requirement for LMRs not that long ago. At a minimum, the status quo for LMR accreditation should be maintained until all of MISO’s recent changes to LMR participation in MISO have been fully implemented and the impacts thereof become fully known. Keep in mind that many LMRs are businesses that produce something other than demand response and demand response participation is merely a secondary effort by these participants to reduce their operating costs. Frequent changes to LMR rules, additional costly and unnecessary efforts and negative impacts on manufacturing operations, and resulting regulatory uncertainty are disincentives to and negatively impact continued effective participation. Moreover, all LMRs with notification time of 6 hours or less provide value in terms of MISO reliability. MISO has provided no justification or data that supports less than 100% accreditation, much less the 70% and 50% values specifically suggested, which appear to substantially understate the value of certain LMRs and provide inaccurate price signals.
If, despite these considerations, MISO is nonetheless convinced that reduced accreditation based on longer notification times, such as the proposed sliding scale, is needed for LMR accreditation, such a change should ideally come as part of a potential long-term incremental change. Under such circumstances, the following sliding scale would seem to be much more simple, straightforward, reasonable and acceptable:
0 to 3 hours = 100%
3 to 6 hours = 80%
Even then MISO should provide justification and produce data to stakeholders that supports any proposed percentage accreditation less than 100%, with further stakeholder discussion needed thereafter.
[1] Ensuring that load increases do not materialize is just as important as load reductions at times when the system is stressed.
[2] If Peak Demand is used, it should be the highest demand in each season and the calculation should be adjusted upward to reflect any self-curtailment for economic or other purposes and to reflect reduced load due to operational factors.
It would be helpful to have an LMR workshop where the proposal terms could be more clearly discussed and refined.