Minnesota Power appreciates the opportunity to provide stakeholder feedback on proposed LMR changes. 

 -          The MISO loads for August 24, 2023 appear to be instructive in challenging the premise of MISO stating that there is a disconnect of planning to operations.  The MISO load forecast was showing a maximum demand of over 127 GW, but the MISO members bid load was showing a peak of 121 GW, which turned out to be the actual peak load and hourly pattern of a flat load pattern for peak hours.  The details on the declared disconnect has been stated by MISO, but the actual information showing this disconnect has not been presented. 

-          There are stated concerns about only being able to use LMRs at an EEA2.  It is our understanding that scheduling instructions can be given for a Max Gen Warning/Alert.  Please clarify if there is more flexibility and what conditions allow calling on the LMR.

-          There is a concern on the viability and customer acceptance of a 30 min startup requirement for emergency resources.  The impact could result in less customer acceptance of LMR, due to customers not being willing or able to provide a 30 min LMR startup. 

-          There is reference to a sliding scale for accreditation for non-emergency resources. Text from slide Accredit non-emergency LMR on a sliding scale based on notification time. The longer the notification time, the less accreditation received“  Minnesota Power also believes that the duration of the LMR is an important attributed.  Please clarify the details on this proposed concept

-          There is a stated 100% weighting for Tier 2 hours for LMR accreditation, and yet the disclosure of Tier 1 and Tier 2 hours is not provided until after-the fact.  It is possible that some hours for LMR implementation that may not be Tier 2 hours. There is quite a bit of confusion on how Tier 2 hours and LMR accreditation will be constructed.   

-          For the ICCP requirement, it is not clear the need for this, and depending on the type of LMR, it will have a significant impact on the viability of continuing to implement the LMR. 

-          Consistent application of the PRM % and transmission loss gross ups needs to occur for both BTMG and DRRs.

The following feedback is offered by The Entergy Operating Companies ("EOCs or Entergy”) in response to the request made during the August 22, 2023 Resource Adequacy Subcommittee for stakeholder comments on MISO’s proposed short-term and long-term changes to market rules regarding LMR participation and accreditation. As explained more fully below, the EOCs have significant concerns about the proposed changes to the LMR participation rules. These changes, if implemented as currently proposed, carry significant risk of driving LMRs out of the market over a short period of time and creating a capacity shortfall. Moreover, MISO has not explained why the proposed changes, particularly the unreasonably short 30-minute notice period that 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.

In the short-term, MISO proposed to make changes to the Demand Side Resource Interface (DSRI) tool to collect locational and availability data for each LMR as well as propose additional instrumentation needs. The EOCs have concerns about these proposed changes for a few reasons:

1. Some LMRs in the Entergy fleet may encompass loads sited in multiple zip codes, which makes   reporting locational information for the aggregation of these units difficult. 
2. Requiring LMRs to have ICCP (Inter-Control Center Communications Protocol) connections will be a very difficult process for MP’s. The installation and integration of the equipment needed to provide this capability could be difficult and costly to achieve.
3. While MISO may be in a position to implement these changes in the short term, it could take quite some time for an MP’s internal IT and other staff to make the necessary changes to install and deploy the necessary equipment. 

Entergy has significant concerns about the long-term proposal of separating LMRs into two categories (Emergency and Non-Emergency) for the reasons stated below:

1. The term “Emergency” is important for some of Entergy’s retail tariffs that allow our LMR customers to participate, reclassifying LMR’s into MISO’s “NON Emergency” category could create conflicts with existing retail tariff language and cause current loads participating in the market as LMRs to cease participating. It would also require the EOC’s to revise retail tariffs, which carries risk and uncertainty.
2. The EOCs consider the proposed new “30 minute notification time” to be unreasonable short notice and urge MISO to reconsider this drastic change; at a minimum, MISO should provide additional analysis or information to support the needs, drivers, and benefits of such a short notice timeframe for LMRs. It is important to note that MISO somewhat recently reduced the LMR notification time, phasing out LMR that require more than 6 hours’ notice. This change took effect for the 2021 – 2022 Planning year. Now, MISO is proposing a substantial further reduction in the notice time, with no clear explanation to the Stakeholder regarding the justification for this change. In MISO current model, LMRs capacity is counted fully toward the PRMR, however in the proposed strawman, non-emergency LMRs would receive much less accreditation, if any at all. The EOCs believe it is highly likely that the new proposed drastic reduction in notice to 30 minutes will result in many LMRs exiting the market instead of participating as a non-emergency LMR, which could have harmful consequences to the LSEs and their customers, particularly considering the tightening market conditions arising from resource transition. It would also require the EOC’s to revise retail tariffs, which, again, carries risk and uncertainty.
3. Consistent with the concerns above, the EOCs believe that the proposed reclassification of LMRs into the 2 defined categories and the sharp reduction in the notice times that MISO is proposing could lead to a capacity shortage in MISO due to the sudden unenrollment of numerous LMR units, with little time for LSEs to adapt their planning or react and due to the negative impact on the revenue that LMRs currently receive from their participation in the MISO markets.
4. MISO can call on LMRs in anticipation of a Step 2A event, thus negating the necessity of a 30 minute notification period. Should MISO Operators anticipate the need for LMRs, they can schedule those similar to how they currently routinely schedule generation resources for reliability reasons in the RAC process.

It seems MISO has taken a “nice to have but not necessary” proposal to the RASC, and not considered the extreme impact it would have on LMRs and what LMRs would be available to the MISO Market going forward if this long-term proposal would be implemented. We look forward to working with MISO, and welcome direct discussion with MISO: to understand how the EOCs look at LMRs as potential tool for our transitioning fleet, understanding our LMRs in more detail, how we can collectively improve communication and cooperation around optimizing LMR deployment in Emergency conditions, and steps MISO could take to possibly increase (and not decrease) Demand Response and Distributed Energy Resources available to MISO to ultimately improve reliability.

1. The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.

Xcel Energy appreciates the opportunity to provide feedback regarding MISO's latest LMR proposal but believe additional discussions needs to occur at the RASC to develop a reasonable proposal and transition. 

We reiterate our support to incorporate location information for LMRs to identify the load resources that will be impactful during an emergency event when there is a binding constraint that splits an LBA.  MISO needs this information to provide accurate scheduling instructions immediately instead of through a manual process between the MISO RC and the LBA.  It is likely that this manual process will also have another layer of communication as the LBA will need to coordinate with the LSE.   Time and accuracy is of the essence during emergency events and a manual process for LMR instructions takes operators away from other critical activities required for managing reliability.  Providing the locational information for LMRs within an LBA is also a necessary step for MISO to move towards a declaration area for an emergency event that is more granular than today's LBA restriction.

Our preferred solution would be to provide the EP node (distribution/transmission substation) that each LMR is connected to.  This would still allow MISO to determine the amount of load relief within a particular area based on substations which MISO has included in their models.  Since the substation would be a fairly static location for each LMR and identified at one point in time, the control sub-groups would be readily available within the normal notification times. 

MISO needs to allow time for LSEs to identify and incorporate the substation assignment into the registration and MCS processes.  In addition, upgrades to both the MECT and the MCS will need to be developed before this information can be submitted and processed efficiently.   MISO cannot require LMR group registration by zip code or EP node 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.

We are open to accrediting LMRs based on availability during seasonal Tier 2 hours as long as self-scheduled amounts are included in the accreditation calculations.  It does not matter if MISO requests curtailment of an LMR through scheduling instructions or an LSE/ARC instructs the LMR to curtail, they are both reduction of load that is included in the PRMR requirements and should therefore receive capacity credit.

Xcel Energy does not agree with the 30-minute notification time requirement for capacity credit as an emergency only LMR.  We would be open to a 2-hour notification threshold or allowing access to LMRs earlier in the Emergency procedures but believe that additional discussion is needed at the RASC to develop a more reasonable approach. 

Requiring LMRs to register as DRR-Type I or DRR-Type II will likely reduce the available capacity of these resources as metering requirements for these resources are cost-prohibitive for small resources.  MISO has proposed to develop DEAR market participation models.  It would be reasonable to wait until the implementation of O2222 compliance is required by FERC to leverage these new market participation models.

MISO's proposal would accredit Non-Emergency LMRs (which are registered as a DRR) on a sliding scale based on notification time.  A DRR is treated in the market very similarly to a generator, so we request that MISO explain why DRRs would be registered on a sliding scale based on notification time? 

Consumers Energy wants to thank MISO for the opportunity to provide feedback on the LMR accreditation and overall agrees for the need for change to support the reliability of the grid in the future with change resource make-up. Consumers Energy generally supports the LMR accreditation changes tying capacity value awarded to the availability of the resource during periods of highest reliability risk.

Near-Term: DSRI Enhancements and LMR Accreditation

In MISO’s 20230822-23 RASC Item 09biii LMR Accreditation (RASC-2019-9) presentation, slide 5 shows that Intermittent BTMG will have a new requirement to provide hourly data to the Demand Side Resource Interface to allow the operators to leverage this resources availability during emergencies.  Consumers Energy feels that Intermittent BTMG add no value or visibility for MISO as they are typically generating maximum output based on fuel availability 24/7/365 and should be removed from the DRSI tool.  Consumers Energy would like to better understand the data behind the value of inputting these values daily which seems to only create more reporting burden to the balancing authority operators, without any added reliability to the grid.

Consumers Energy does agree with the enhancements of the additional fields and the leveraging the availability during define hours per season for Demand Response Resources specifically and supports this for DRR.

Consumers Energy would also like to further understand the benefit of inputting location information in the registration process and the supporting data behind how this will allow for more effective operations, since most DRR are used to reduce load which should decrease the stain on the overall system.

MISO’s Long-Term Straw Proposal

Consumers Energy agrees with MISO that there is a need to be able to better understand and award faster responding LMRs in an emergency and would be in support of discussion of a sliding scale for capacity accreditation based on notification time for all LMRs and would like to understand the benefit of creating two categories instead of just properly accrediting resources based on their response time? 

Consumers Energy is concerned with placing Demand Response Resources into the non-Emergency LMRs and diminishing the value of these resources and the support they provide during an emergency.  Both MISO and market participants have benchmarked and shown that they provide value, however most will not be able to follow the provisions required if they participate in the Market like other generation resources, which could decrease participation.  Consumers Energy would also be open to consideration of LMRs by resource type requiring different start times.

AMES, AMP, and MPPA support WPPI's feedback.

Happy to discuss.

David Sapper

dsapper@ces-ltd.com

CPower Comments to MISO’s August 22-23 RASC Feedback Request on Accreditation Reforms for Load Modifying Resources

September 14, 2023

During the August 22-23 RASC meeting, MISO presented its proposal for accreditation reforms for Load Modifying Resources (“LMR”). Enerwise Global Technologies, LLC d/b/a CPower (“CPower”) appreciates the opportunity to provide feedback to MISO on its proposal and thanks MISO staff for their review and consideration. Should you have any questions, please do not hesitate to contact Peter Dotson-Westphalen.

Near-Term Proposal

CPower supports MISO’s proposal to collect additional locational information at the time of registration to improve operator visibility to where the aggregated participating accounts that comprise each LMR are located to better address and manage emergency operating conditions. However, MISO should not make changes to the ability for Market Participants (“MP”) from forming LMR aggregations at the CPNode level. Aggregation across the broadest possible geographic area helps to enable more participation, and limiting to a single EPNode may prevent otherwise-capable customers (particularly smaller customers) from being eligible to participate if the MP representing the customer cannot meet the minimum aggregation size as a result. As more customers are adopting technologies that can enable participation, it seems short-sighted to limit the scope of aggregation and leave capable resources out of the market. Limiting aggregation to the EPNode also limits a valuable tool to MPs to balance performance of the resource during dispatches.

CPower understands MISO’s proposed approach to align capacity accreditation to all resource types to create parity. However, CPower is concerned that the use of historic seasonal LMR availability in the DSRI based upon hours known only after they have occurred does will adversely impact LMRs, particularly LMRs registered utilizing firm service levels (“FSL”), and understanding what will count towards LMR availability to inform accreditation calculations.

Additionally, CPower believes further work is necessary as a part of this effort to align MISO’s methodologies for assessing performance during events and tests. Currently, MISO assesses LMR test performance based upon a “meter before, meter after” approach utilizing the hourly data from the resource prior to the designated notification lead time for the resource and subtracting the meter read from the test hour, which is both not documented anywhere currently in MISO’s Tariff or Business Practice Manuals. It also does not follow the event performance evaluation methods specified in Attachment TT of the Tariff. While MISO does allow test results to be scaled to customers’ seasonal peak demands, and allows for registration of values higher than the value observed in the test performance,[1] the fact still remains that an energy baseline is used for a capacity product, and the test performance must be at least 50% of the registration MW (which is also capped at the seasonal average coincident peak demand of the customer accounts comprising the LMR). We recommend folding alignment of test and event performance evaluation methodologies, and to make sure all are clearly stated in MISO’s documentation.

Long-Term Proposal

MISO’s proposed changes to the LMR construct in the long-term include creating new “Emergency-Only, and “Non-Emergency” LMR types. Emergency-Only LMRs will be required to have a maximum notification time and be highly reliable. Non-Emergency LMRs would be required to participate in the energy market, utilizing the DRR construct to be able to access Non-Emergency LMRs with longer lead times. MISO also plans to require both LMR types to utilize real time telemetry via ICCP, as well as prohibit dual registration of LMRs as EDRs. MISO intends to continue applying Transmission Losses and Planning Reserve Margin to LMR registered MW.

CPower doesn’t necessarily disagree that there may be merits to changes to the LMR construct to allow MISO to access longer lead-time LMRs to address system conditions. But we do caution that requiring participation in the energy market may result in attrition from the program by placing higher requirements (and potential risks and potential penalties) on those resources, for which it may not be cost effective to continue participating, or customers may not be interested in assuming additional risk. Most customers participating as LMRs to provide emergency capacity are willing to help support reliability of the grid, but many are not capable of or wish to incur the costs and additional administrative burden associated with participating as a DRR.

CPower understands disallowing dual registration to participate as an LMR and EDR if required to participate as a DRR in the energy market for Non-Emergency LMR, but dual registration as an EDR should remain on the table for discussion for Emergency-Only LMRs. Currently, LMRs are only eligible to receive capacity credit, and are dispatched before EDRs in MISO’s Emergency Operating Procedures. Customers that bear the risk of more frequent interruption by committing to participate as LMRs should have some mechanism available to earn energy payments when they are dispatched to recoup their costs (or lost opportunity costs) of performing when dispatched by MISO to support the grid. Some form of energy payment should be available to all LMRs that does not require the full burden associated with participation in the energy market. Additionally, if MISO does plan to scale the capacity accredited to Non-Emergency LMRs with longer lead times, this scaling should be aligned to that of any other resource type that also requires similar notification lead times to respond to MISO dispatch.

CPower does not support MISO’s proposal utilizing telemetry via ICCP, even if just at the LMR level, to provide operational visibility. ICCP connections can be expensive for MPs to set up and maintain, while suitable, more cost-effective, solutions to allow near-real time visibility into the availability and performance of the resource could be provided. CPower recommends further discussion and consideration in the stakeholder process of alternatives to telemetry via ICCP to address the root of MISO’s operational concerns. Additionally, MISO’s proposal would, by referencing energy market participation for Non-Emergency LMRs as DRRs, introduce a requirement for DRR Type I resources to also provide telemetry via ICCP, which may be beyond the scope of the discussion around LMR accreditation reform.

CPower supports retaining the Transmission Losses and Planning Reserve Margin.

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

MidAmerican Energy appreciates the opportunity to provide feedback on LMR Accreditation (RASC-2019-9) (20230822-23).

MidAmerican understand why MISO is trying to separate LMRs into two categories: Non-Emergency and Emergency Only but MISO needs to understand that some of the demand side programs are purely designed as Emergency Only and changes like this will require regulatory filings and will be subject to state approval. If regulatory approval isn’t obtained, then both the MP and MISO may have just lost access to capacity in a time where the system needs more capacity and not less. Another issue that MISO needs to consider is that limiting Emergency-Only LMRs to a 30-minute start time may severely limit participation in these voluntary programs. It would stand to reason that MISO would rather have all the MWs available to them possible and it seems unreasonable to think that access to load reduction in 4 hours is better than no access at all in the event of emergency conditions. Having Non-Emergency LMRs participate in the energy market also has issues, such as a requirement for that LMR to have daily (365 days a year) communication with the market participant which will also likely result in lower participation. Taking steps that potentially lower LMR participation is something the MISO should not do haphazardly.  

In addition, MidAmerican has the following specific questions/comments about the presentation:

Slide 5

Utilize DSRI to leverage availability during defined hours

• Can MISO clarify what “defined hours” are for BTMG and DR resources?

In reviewing BPM-011 hours are defined for EE Resources but not defined for BTMG or DR resources directly.

Require locational information through the registration/qualification process

In BPM-011 r29 4.2.6 BTMG Qualification Requirements, the added bullet states, “Submitting the zip code for the physical location of all generators in the BTMG registration.  Generators located in separate zip codes must be registered separately.”

• Submitting these as separate registrations will be an administrative burden for MidAmerican but also for MISO. Is MISO prepared to have 32 times more data points (x32)? MidAmerican’s BTMG groups would increase to be 32 times larger. 
• Can MISO have some sort of automation in the DSRI tool through uploads or something similar?

In BPM-011 r29 4.2.7 Demand Resource (DR) – Qualification Requirements, the added bullet states, “Submitting locational information for each asset in the DR registration. That information can include Account Number, Meter Number, Address, City, State, and Zip Code. The minimum required information is the Zip Code for every physical location of the asset in the DR Registration. ARCs must submit all locational information listed above.” 

• MidAmerican has a program that controls air conditioners throughout the state of Iowa. Did MISO consider that in this proposal, and would this requirement apply for programs such as this?

Slide 9

• Can MISO provide further information on “offer parameters” and limitations? (i.e. MidAmerican would need guidance as to what an acceptable use of the offer cap would be)
• MISO indicates “Flag LMRs as only available under certain conditions…” Can MISO detail what these conditions are?

Comments on MISO Initial LMR Accreditation Proposal (RASC-2019-9)

Submitted by Thomas Siegrist, SMXB Consulting Engineer

During the MISO Resource Adequacy Subcommittee (RASC) Meeting held August 23, 2023, MISO requested feedback on its Load Modifying Resource (LMR) Accreditation proposal. 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.  Given the limited information we have at this point, our views may change as we obtain more information and have a chance to further consider the issues, so we reserve the right to supplement and/or change our comments.  We appreciate the opportunity to comment.

Our primary concerns at this early point in the process focus on issues of availability/reliability and notice, which depending on the course of action MISO ultimately adopts, could have a negative effect on LMRs and consequently on the reliability of the MISO system.

MISO staff’s presentation sets forth its proposed approach for near-term/long-term changes to LMR accreditation.  Principally, MISO indicated that it plans to determine LMR accreditation based on the capability and availability of a resource during the periods of highest reliability risk.  More specifically, as we understand it, MISO’s recommendation for LMR accreditation reform consists of the following:

• Proposed Near-Term Changes
  • Require locational information for LMRs.
  • Modifications to MISO’s Demand Side Resource Interface (DSRI) Tool to improve tracking of LMR availability.
  • Long-Term Strawman Proposal
    • Separation of LMRs into two categories: (i) Non-Emergency and (ii) Emergency Only.
      • Non-Emergency LMRs would participate in the Energy Market.
      • Emergency-Only LMRs would continue to be called on only during EEA-2 Events but would be required to meet a 30-minute (or less) notification time.
• As to accreditation:
  • Non-Emergency LMRs would be accredited on a sliding scale based on notification time.  The longer the notification time, the less accreditation received.
  • Emergency-Only LMRs would be accredited at 100% of verified capacity.

Our first and foremost issue is the treatment of Firm Service Level (FSL) LMRs in determining availability and accreditation.  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 called.  If the load drops down to its FSL, and stays there for the requested duration, then the LMR should be regarded as 100% available and compliant.  Ensuring that load increases do not materialize is just as important as load reductions at times when the system is stressed. 

While the FSL issue has already been communicated by various stakeholders to MISO, at this point MISO has not indicated how it will be addressed.  This issue was spelled out in the presentation made to the RASC by Jim Dauphinais of Brubaker & Associates, Inc. on behalf of the End-Use Customer Sector on January 17, 2023.  We share many of the concerns set forth therein and note that this issue does not appear to have been resolved by MISO’s proposed modifications to the DSRI Tool (at least as evidenced by the “example” provided at page 7 of MISO’s 8/23/23 presentation).  As a result, we are particularly concerned with any potential changes MISO may make that would negatively affect (or not adequately address) the FSL option. 

Additionally, we have concerns regarding MISO’s long-term strawman proposal to establish a 30-minute notification requirement to qualify as an Emergency-Only LMR and move all other LMRs to the Energy Market:

• First, a move from the current 6-hour notice requirement to a 30-minute notice requirement is far too aggressive a change. Such a drastic reduction in the permitted emergency notice requirement will compromise MISO system reliability when it is most at risk by reducing the amount of LMR load available to be called upon.  Moreover, potential participation by LMRs in MISO’s Energy Market is not a reasonable replacement for LMRs required to curtail during an emergency. While reduced notice may be preferable to MISO, promoting a one-size-fits-all 30 minutes notice requirement makes “the perfect the enemy of the good ….”  The result will likely be to simply eliminate all emergency LMRs who need more than 30-minutes notice. LMRs with much greater than 30-minutes notice requirements inarguably provide value during emergency events. There is no reason not to have Emergency-Only LMRs with varying notice periods running from 6 hours to 30 minutes.    

• Second, a 30-minute notice requirement would seemingly be much more challenging for many LMRs and may result in the need for some LMRs (assuming they remain LMRs) to adjust their respective FSLs higher at an increased cost to the customer and the related loss of LMR megawatts to the system. 

• Third, at the outset, MISO recognized LMRs as planning resources, with notice times similar to generation resources.  With its latest proposal, MISO has equated LMRs to operating reserves to receive “full accreditation.”  This appears to be inconsistent with how MISO accredits generation resources.  That is, a generation resource with a start up time of 12 hours is not penalized by receiving less capacity credit than a resource that has a start time less than 30 minutes. While shorter notice periods may be possible for some LMRs, in many cases it is not without negative impact to the LMR’s cost of operation.  If MISO ultimately adopts such changes for LMRs, which we do not recommend, then we strongly suggest an enhancement to accreditation (an adder to the present accreditation) that reflects this new, enhanced method of operation. 

MISO needs to be cognizant of state-approved tariff impacts on LMR flexibility. Also, customers may exit LMR programs quickly if operations are perceived to become undesirable due to high frequency and/or short reaction time.  If MISO squeezes too hard on accreditation rules and flexibility requirements, program participation could easy drop and MISO would be left with fewer options for its operators.

MISO should accommodate resources of all kinds and lead times, even if not available for short-term emergency response. Here again, this provides options and flexibility for operators in the Day Ahead market.

MISO should have a large MW threshold to accommodate some amount of aggregate LMRs, as reporting granular LMRs at an EP Node level would be too cumbersome. For example, 100-300 MW for a LMR program aggregated to a state level seems reasonable. We are curious to hear from MISO some specific examples of larger programs that are problematic for operators. Surely the 80/20 rule can be applied to focus on a few specific issues as opposed to impacting all programs. Another option is to have LSEs roughly estimate the percentage of contribution by EP Node for each of its LMR programs.

The 30-minute response time proposed by MISO appears unobtainable for typical LMR programs. MISO could survey stakeholders on realistic response times to determine what LMR programs would be left within the 30-minute window.

Alliant Energy encourages MISO to further discussions by identifying problem areas of the footprint, and/or generic examples of typically problematic LMR programs. That way MISO and stakeholders can focus on true root-cause issues as opposed to making broad, sweeping changes that may ultimately result in less operator flexibility.

As originally voiced by Great River Energy, MISO should not require forecasted hourly data on Intermittent BTMGs. Reporting such weather-dependent data is overly burdensome for MPs. MISO could easily create its own generic assumptions on hourly profiles for these resources.

WPPI is generally comfortable with MISO’s proposed near-term changes.  We note that the location information that MISO wants is probably better characterized in terms of Network Model Bus Number rather than EPNode name, since multiple EPNodes at a given bus would appear to have the same locational impact.

In contrast, WPPI has several concerns with MISO’s proposed long-term strawman:

1.  At the August 23 RASC meeting, MISO indicated that the proposed 30-minute maximum notification time for emergency resources was based on consultation with MISO operators.  But it is not appropriate to simply set requirements based on operators’ professed preferences without considering whether such an approach is consistent with providing resource adequacy in a cost-effective manner.  Before making further changes to LMR notification-time requirements, MISO and stakeholders together need to evaluate, among other things: what MISO’s current needs are; what MISO’s expected future needs will be, accounting for expected very substantial increases in battery storage and flexible demand associated with vehicle charging; the makeup of existing LMRs; why various resource types may need different notification times; difficulties posed by having to meet an every-day must-offer requirement; and existing and future avenues for LMRs to participate in MISO’s markets on known low-margin days.

2. MISO’s presentation describes that MISO operations cannot access LMRs absent an EEA2.  This fails to tell the complete story.  MISO has the ability to pre-schedule long-lead LMRs in anticipation of capacity shortages such that these resources can be available in the event an EEA2 occurs.  Rather than ignoring this capability, MISO should describe how they are making use of it under existing rules and specifically identify any shortcomings with the existing process.

3.  MISO says that future emergency-only LMRs must be highly flexible and reliable.  Per discussion at RASC, MISO says that “highly flexible” here is intended to mean nothing more than maximum notification time of 30 minutes, which makes this criterion entirely duplicative.  Moreover, we disagree that emergency-only LMRs must be highly reliable.  Resource reliability is accounted for in accreditation.  There is no reasonable need for an additional reliability requirement.  We understand that MISO is using this “highly flexible and reliable” language for emphasis, but would request that MISO remove it from future discussion, as it serves only to introduce vagueness and imprecision.  

4.  MISO proposes to “[a]ccredit non-emergency LMRs on a sliding scale based on notification time.”  To the extent MISO plans to apply a must-offer requirement to such resources similar to the existing Capacity Resource requirement, this would introduce inconsistent accreditation treatment that appears improper.

5.  Finally, as WPPI has previously raised in operations forums, we see a significant need for the DSRI tool screens to talk to each other.  Specifically, the tool should be made to function such that when MISO issues scheduling instructions based on reported availability of LMRs, and the LMR Asset Owner submits its final planned deployment to MISO, the DSRI availability tool AUTOMATICALLY adjusts and shows the available MW quantity reduced by the amount of the submission to MISO.  Currently the tool does not function this way.  This is the one process with a very large potential for error as currently there is risk that MISO could double-deploy assets if they call on a second round of LMRs.  It is WPPI’s position that this is a critical feature to be incorporated into the DSRI.

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 (RASC-2019-9) (20230822-23)

September 14, 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 August 22-23, 2023, meeting of the MISO Resource Adequacy Subcommittee (RASC), after a hiatus from this past January, MISO returned to the subject of Load Modifying Resource (LMR) capacity accreditation.  Specifically, in its August 22-23 presentation, MISO presented straw proposals for both near-term and long-term changes with respect to LMRs.

The proposed changes in the near-term straw proposal include:

• Adding additional fields for the MISO Demand Side Resource Interface (DSRI) to improve tracking of LMR availability;

• Basing LMR capacity accreditation based on availability data in the MISO DSRI during defined hours;

• Requiring location information, in the form of zip codes, for all LMRs during registration; and

• MISO mapping LMRs to EPNodes based on the provided zip code information.

The proposed changes in the long-term straw proposal include:

• LMRs requiring more than 30 minutes of notification being designated as Non-Emergency LMRs;

• Non-Emergency LMRs being able to use the Demand Response Resource Type I and Type II constructs and submit offers, limits and notification times;

• MISO Operations being able to access Non-Emergency LMRs prior to emergency conditions;

• Non-Emergency LMRs being capacity accredited on a sliding scale based on notification times;

• Emergency Only LMRs being required to be highly flexible, reliable and have a maximum start time of 30 minutes;

• Both types of LMRs being required to have a ICCP connection; and

• LMRs no longer being allowed to be dually registered as Emergency Demand Response (EDR).

MISO made clear in its presentation that the straw proposals were only a starting point for discussions with stakeholders.

ABATE, IIEC, LEUG, TIEC, CMTC, MIC and NLCG appreciate MISO’s framing of its straw proposals as just a starting point for discussions.  Furthermore, we look forward to working with MISO over the coming months to address MISO’s 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.  To that end, we 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.  

MISO’s Near-Term Straw Proposal

We have the following preliminary comments on MISO’s near-term straw proposal:

• Further discussion of MISO’s proposed additional fields for the DSRI is needed.  In particular, as we discussed in our January 17, 2023 Presentation to the MISO RASC on LMR Demand Resources using the Firm Service Level Option, great care is needed with respect to collecting information on LMR Demand Resources using the Firm Service Level option if that data is going to be used as a basis of their availability for capacity accreditation purposes.[2]  As that presentation emphasized, LMR Demand Resources using the Firm Service Level are intended to provide MISO Operations with the ability to remove all of the non-firm load associated with these LMRs from the MISO system when these LMRs are called upon such that MISO does not need to carry capacity for that load in order to maintain resource adequacy.  They are not a form of operating reserves and do not need to be a form of operating reserves to allow MISO to avoid a need to carry capacity for the non-firm load associated with them.[3]

• MISO’s proposal on Slide 7 that “Self Scheduled MWs by MP” not be subject to the LMRs notification time is highly problematic.  In particular, it should be noted that some industrial customer processes are constantly in motion and cannot be forecasted on a guaranteed basis.  For example, assume an industrial customer with a Firm Service Level of 0 MW and a registered demand reduction capability of 100 MW.  Also assume that for a future hour the customer as a LMR is forecasting a demand of 50 MW.  To reflect this, the customer enters 50 MW (100 MW – 50 MW) into the DSRI as “Self-Scheduled MWs by MP” and 50 MW into the DSRI as “MWs Available to MISO”.  This reflects the customer’s best estimate of what additional load curtailment will occur if MISO was to issue a LMR scheduling instruction to the customer to curtail its demand down to its Firm Service Level of 0 MW.  However, all that the customer can guarantee to MISO is that the customer can be reduce its demand down to its Firm Service Level of 0 MW if MISO issues it a scheduling instruction with the proper notice.  The customer is incapable of guaranteeing that its demand in that future hour will actually be at or below 50 MW with no notice from MISO.  As a result, if MISO were to require that the customer make its “Self-Scheduled MWs by MP” available with no notice for that future hour, the customer would have no alternative available other than to report its “Self-Scheduled MWs by MP” for that hour as 0 MW and its “MWs Available to MISO” for that hour as 100 MW even though the customer is forecasting its demand for that hour to be 50 MW rather than 100 MW.   

• As we have commented in the past, data collected from the MISO DSRI should not be used as a basis of LMR availability for capacity accreditation until: (i) the DSRI has been fully modified to collect all of the necessary information; (ii) clear direction and notice has been given with respect to when LMRs must start reporting the necessary information in the DSRI; and (iii) at least a full year’s worth of data has been collected in the DSRI from the first date upon which the reporting was required to begin.[4]

• MISO’s proposal to use zip codes at the time of LMR registration to obtain locational information on LMRs and then translate that into EPNode information for MISO Operations is unworkable for LMR aggregation and may yield inaccurate information with respect to EPNodes.  Furthermore, as we have commented in the past, collecting the CPNode for each LMR at the time of registration should provide sufficiently granular locational information for MISO Operations.[5]  Each CPNode already has an EPnode mapping associated with it allowing the locations to be modeled in MISO’s network topology.  Furthermore, unlike with requiring zip code or EPNode information, requiring CPNode information would not interfere with LMR aggregation.         

MISO’s Long-Term Straw Proposal

• MISO’s preliminary proposed changes under its long-term straw proposal are much more aggressive than those under its near-term straw proposal.  As a result, they will need much more time to allow for adequate analysis and vetting with stakeholders.  They should not be included with the near-term changes that MISO expects to file with FERC by the end of the 2^nd quarter of 2024 and instead be the subject of a separate later filing if they are ultimately pursued by MISO.

• MISO has not at this time justified a 30 minute notice cutoff for Emergency Only LMRs.  As a minimum, the proposed cutoff for Emergency Only LMRs should be extended to up to a 2 hour notice.  LMRs are not operating reserves.[6]  As we have commented in the past, if MISO believes it needs on-call MW of a specified amount with only 30 minutes of notice, MISO needs to create a new operating reserve product to provide this from generation resources, energy storage resources and Demand Resource Resources.[7]  LMRs, especially those using the Firm Service Level option, were never intended to provide such a product[8] and MISO should not try to force fit them into providing such a product.

• MISO’s long term proposal contemplates that all LMRs which cannot respond within 30 minutes of notice would be Non-Emergency LMRs.  It appears under MISO’s proposal that Non-Emergency LMR would be required to participate in the market as Demand Response Resources or in a manner similar to Demand Response Resources. The End-Use Customer Sector opposes this approach and finds this proposal to be unworkable due to the additional requirements for Demand Response Resources and the fact that there is not a Firm Service Level option available under MISO’s Demand Response Resource provisions.   Non-Emergency LMRs should not be required to be Demand Response Resources or to meet requirements similar to Demand Response Resources.  Introducing such problematic requirements would result in reducing LMR participation at a time when MISO needs such resources to help maintain resource adequacy.

• With regard to access to longer lead time LMRs before Maximum Generation Step 2a is reached, MISO already has a process which it uses to gain access to longer lead time LMRs when they are needed.  For example, on August 24, 2023, MISO declared a Maximum Generation Event at Step 2a at 8 AM to begin at Noon.  This resulted in eliciting 1,300 MW of voluntary demand response, which, when coupled with lower load than predicted, resulted in MISO not needing to actually issue scheduling instructions to LMRs and the situation not degrading beyond Maximum Generation Event Step 2a. Furthermore, even if load had been as been as predicted and the 1,300 MW of voluntary demand response had not appeared, MISO would have still had access to long lead time LMRs during that afternoon (e.g., 6 hour notice LMRs by 2 PM).  Consequently, MISO should clarify in a future presentation what issue it is aiming to address by wanting even earlier access to longer lead time LMRs.

• We are open to further discussing the potential use of a sliding scale for capacity accreditation for Non-Emergency LMRs based on notification time provided it is fully supported by loss of load probability analysis that has been reasonably performed.

• MISO has not shown that there is a reliability need to require all LMRs to have a costly ICCP communications connection.  As such, the proposed requirement needs to be fully justified by MISO or dropped.

• MISO has not shown there is a need to eliminate dual registration of LMRs as EDR.  As such, this proposed change needs to be fully justified by MISO or dropped.

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

jdauphinais@consultbai.com

Ali Al-Jabir

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(361) 994-1767

aaljabir@consultbai.com

Ken Stark

McNees Wallace & Nurick LLC (for CMTC)

(717) 237-5378

kstark@mcneeslaw.com

Kavita Maini

KM Energy Consulting, LLC (Consultants to MIC)

(262) 646-3981

kmaini@wi.rr.com

WEC Energy Group offers this feedback on MISO’s Accreditation Reforms for Load Modifying Resources presentation dated August 23, 2022. 

1. While we understand the need to ensure appropriate LMR capacity accreditation and reliable performance of LMRs during critical events, MISO needs to recognize that for many customers, their willingness to curtail their load during MISO events is driven by the incentives they receive from their local utility/load serving entity under their retail rates to enroll in a non-firm rate.  Utilities are able to provide retail rate incentives based on the reduction in costs to their firm customers through reduced capacity and energy costs.  To the extent MISO devalues LMRs, retail rate incentives for participating in non-firm rate programs will tend to decline, and customers will tend to move from non-firm rates to firm rates, reducing the size of the LMR pool.  As LMR deployments increase (as expected) we would also expect to see customers migrating away from non-firm programs and less interest among firm customers to move to a non-firm rate.
2. Allowing the “Non-Emergency LMRs” to participate in the energy market may provide an opportunity for increasing the energy value of LMRs to a load serving entity; if the LMRs also retain significant capacity accreditation value this could provide an overall net increase in LMR value.  Providing event-based (e.g., clearing in the DA market, being deployed in the RT market, etc.) compensation to non-firm load customers would likely require modifications to retail tariffs that would take time for load serving entities to implement.  We have seen limited interest in previous retail tariff offerings that provided event-based compensation, so this structure may take years to provide meaningful impacts.
3. Some LMRs, including the majority of UMERC, WEC, and WPS LMRs, are a collection of individual customers on non-firm rates that are scattered across the LBA. Providing specific locational information beyond the LBA may be of limited value as we do not have the capability to effectively target load reduction commands to individual customers. We have two LMRs that could probably be mapped to EPNodes, but not our other LMRs.
4. We are not aware of any retail customers that would commit to a 30 minute window to implement a load reduction, due to challenges in actually implementing a reduction in load without damaging equipment or sacrificing production in such a short window of time combined with the necessarily substantial penalties that could be imposed for failure to comply with a load reduction instruction.  While a 30 minute LMR would be very valuable to MISO operations, MISO may want to further research just how many MW would actually be available under this proposal prior to investing significant time and resources into its development.
5. The first bullet on slide 4 (“Disconnect between planning and operations…”) is unclear to us; can MISO further explain why this is the case (maybe this explanation occurred at the meeting but we are not aware).
6. Requiring ICCP connectivity for LMRs would be problematic for LMRs consisting of an aggregation of multiple customers scattered across an LBA; some of these customers are quite small.  We would likely be able to accommodate an ICCP connection for the aggregated load of these customers.
7. As MISO contemplate tariff changes to improve the ability to leverage the capabilities of LMRs, MISO should consider providing LMRs with a “Standby for deployment” type of credit. This could facilitate providing advance deployment instructions which may end up being cancelled and could also provide another avenue for load serving entities to create an incentive for non-firm customers to remain on non-firm rates.  At present, many commercial and industrial customers have difficult decisions to make on critical days—send staff home and curtail production in anticipation of receiving load curtailment instructions (expensive) or continue operating as normal until load curtailment instructions are received (potentially very expensive).

 We appreciate the opportunity to provide comments.

 Respectfully submitted,

 Tom Hawley

Director, Power Operations – Power Generation
WEC Energy Group
414-221-4500
tom.hawley@wecenergygroup.com

Duke Feedback to MISO’s LMR Accreditation Proposal (RASC-2019-9) (20230822-23)

ICCP Connection Requirement

                Duke Energy Indiana (DEI) requests clarity regarding the proposed "ICCP connection" requirement for LMRs under this proposal.  During the RASC on 8/22 it was mentioned that individual resources would not require a direct connection to the LMR asset, but instead a connection (by internet, API, or similar) at the aggregation level (i.e.: utility or Market Participant) would be required.  These approaches have drastically different impacts on both MPs and end use customers in many regards (cost, complexity, data privacy, etc.).  DEI suggests that MISO utilize a connection between MISO systems and software systems maintained by the MP (or other aggregator) whereby MISO dispatch orders for individual LMRs can be received and acknowledged in a timely manner.  Such an approach, both in terms of systems and RTO self-dispatch, is utilized by neighboring RTOs (i.e.: PJM).

As noted above, requiring direct connections to LMR assets would increase complexity and cost for end use customers.  Additionally, concerns of data privacy and communication infrastructure would negatively impact total LMR capability for DEI and other MPs.

If asset/device level communication is required, MISO should consider adding support for the DNP3 protocol in addition to specifying which types of LMRs or assets require such a direct connection.  Many vendors support the DNP3 protocol for equipment level control and data collection, whereas very few vendors support ICCP at the device level, which would require additional hardware (communications gateway) installed to enable ICCP communications.  For illustrative purposes, DEI is aware of three (3) RTOs which currently allow or require the DNP3 protocol for device level communications, including PJM, NYISO, and CAISO.

LMR Locational Information

                DEI requests clarity regarding the requested "locational information" outlined in this proposal.  During the RASC on 8/22 it was verbally mentioned only "Zip Code" information would be needed, at least in the short term, but that MISO would take it upon themselves to map the provided Zip Code to an approximate EP Node.  Beyond clarity on the type of locational information needed at the time of registrations, Duke seeks feedback on the related topics:

• Confirm MISO will only require ZIP CODES and require clarity on how MISO will associate these with EP Nodes.  Further, MISO must illustrate how locational information will be entered into the MECT during LMR registration.  DEI suggests MISO collect Zip Code information represented by assets within each registration, but otherwise continue to allow individual registrations to be composed of an aggregation of individual assets within a common CP Node.  Creating individual registrations for each Zip Code (or more granular) would result in the number of registrations increasing exponentially.  DEI has significant concerns MISO's current systems (MECT, DSRI, etc.) are not capable of supporting this quantity of entries.  Further, without MISO self-dispatching resources, MPs would be incapable of manually setting dispatch amounts for this quantity of resources in a timely manner.  MISO should note that many MPs are regulated electric utilities which maintain a mix of dispatchable resources (ex: air-conditioning load control switches) which require communication systems to activate as well as curtailment contracts with large retail customers which curtail load manually in most cases.  Such customers must be communicated with in order to initiate this manual load curtailment.  Maintaining the ability to aggregate these end use customers within LMRs is critical to successful dispatch of these resources.
  
  
• Clarity on how locational information will impact event compliance and settlements.  MISO should consider overall settlement at the MP / utility level.  This would allow the MP to retain a measure of diversity in how each individual LMR performs.  DEI suggests MISO revise compliance and settlement processes to take place at the level of all resources / registrations for each Market Participant.  This would preserve a level of diversity currently reflected in aggregations of individual assets within common LMR registrations and would more fairly assess overall LMR performance.  For contrast, today an LMR utilizing a FSL compliance methodology may curtail more load than requested by MISO, but if the registered FSL is not achieved, the LMR will be penalized, and actual load curtailment not acknowledged.  LMR registrations representing an aggregation of many end use customers essentially assists in allowing for some diversity in terms of individual end use customer performance.  Any revision to LMR accreditation processes which results in a shift from a relatively low number of LMR registrations composed of a large number of individual end use customers to a relatively high number of LMR registrations composed of a small number of individual end use customers will negatively impact both the ability of any single LMR registration meeting the minimum 100 kW requirement as well as negatively impacting the ability of the MP to take advantage of diversity in end use customer curtailments in achieving compliance.  MISO should allow individual LMRs to continue to be composed of an aggregation of various end use customers (even with different Zip Codes) and allow overall compliance and settlement processes to take place at the level of the MP to fairly assess differences in end use customer curtailments.
  
  
• Confirm if MISO would continue to allow LMRs to be composed of individual asset/customer aggregations or if this requirement would result in LMRs being registered per location (zip code, facility site, etc.).  The former appears to be the case based off provided BPM-11 redlines and DEI would suggest that MISO continue to allow LMRs to be composed of aggregations of like assets even across a wide geography.  Particularly in cases of mass market (i.e.: residential) demand response programs, not allowing broad aggregation would result in additional administrative and operational complexity, notwithstanding the issues previously addressed.

DEI again requests MISO self-dispatch LMRs as a key provision in LMR accreditation revisions given all information provided should allow such action and this would further assist Market Participants in meeting more aggressive dispatch timing and requirements.  Additional feedback on this point is provided throughout.

Proposed LMR Types (“Emergency” and “Non-Emergency”)

DEI respectfully notes that timing associated with implementation of these revisions is a significant factor.  DEI maintains several short- and long-term curtailment contracts with retail customers, some of which require formal regulatory commission review and approval.  Revisions to LMR accreditation will impact these contracts and sufficient timing will be needed to allow a smooth transition to new criteria.

DEI also seeks clarity on if either short- or long-term accreditation changes will result in changes to the maximum number of potential events per year for both "Emergency" and "Non-Emergency" type LMRs.  DEI suggests utilizing the same or similar “cap” on maximum potential events by season for both types of LMRs.

Regarding "Non-Emergency" type LMRs, MISO must provide clarity on whether such resources will essentially be Demand Response Resources (“DRR's”) with "must offer" requirements, or if these resources will be more aligned with historical LMRs but are simply called at an earlier step in Emergency Operating Procedures (prior to formal EEA2 declaration).  DEI suggests that even if the energy market systems (DA/RT) are used as a mechanism to call upon "Non-Emergency" LMRs, that such LMRs not be required to maintain energy price / offer bids or similar.  Instead, MISO should simply call upon (dispatch) these resources in alignment with Emergency declarations such as a Max Gen Watch and/or Max Gen Warning.  Most historic LMRs are composed of retail, end use customers who have a willingness to be compensated for load curtailment during times of high system strain.  The nuances between formal EEA 2 declaration and Max Gen Alerts and Warnings are not likely to materially change this willingness to curtail load.  However, essentially forcing such customers to participate in the Energy Market is not a proposal most end use customers have interest in (for the purposes of being considered a type of load modifying resource).

LMR Accreditation based on AVAILABILITY

                DEI seeks clarity regarding how MISO proposes availability (as present in DSRI) be used in the accreditation proposal.  Will these values, likely specific to RA / Tier 2 hours, simply be averaged and this ratio applied to the gross capability registered?  For example, if an LMR is registered at 10 MW, but for the hours in question is only available at 8 MW on average, will the resulting accreditation factor be 80%?

Similarly, DEI seeks clarity on which DSRI fields specifically will be used to determine availability.  Will only the "Available to MISO" field be used or will this in combination with other fields (such as "Maintenance" or "Self-Scheduled") also be used?  It is Duke's suggestion that the sum of these fields should be used.  In alignment with feedback provided by other parties during the 8/22 RASC meeting, MISO must recognize that many Demand Resource LMRs utilize and are quantified based on a Firm Service Level.  Such assets inherently have fluctuating capability and hourly capability values (as reflected in DSRI) which are below the registered amount are almost always a result of these customers having load which is reduced with respect to conditions considered during registration (i.e.: RA/Tier 2 hours, seasonal peak, etc.).  DEI suggests historic availability for Demand Resource LMRs be based off the sum of MW values listed within the "Available to MISO", "Self Scheduled", and the proposed "Reduced Load Availability" rows of the DSRI (as presented during the 8/22 RASC meeting).  In other words, only a true "Outage" of capability should be considered when decrementing LMR accreditation below the registered value for purposes of “Availability”.

LMR Accreditation based on RA / TIER 2 HOURS

                DEI seeks clarity on how the application of RA / Tier 2 hours will impact LMR accreditation.  In the case of DR-type LMRs, will these hours simply direct the capability calculations for purposes of annual / seasonal registration?  Or, will the MISO seasonal peak timing still influence how such LMRs are registered?  In any case, DEI requests MISO support a multi-year averaging or look-back window to reduce year-over-year volatility associated with transient weather and system load conditions impacting these hours.  To further highlight this point, MISO must be aware that many "classic" forms of demand response, such as residential air conditioner cycling programs, have capabilities which are strongly correlated with system peak conditions typically accompanied by high temperatures.  If the hours and conditions used to accredit LMR capability are highly variable each year, such offerings may be difficult to maintain at the retail level such that if they are again needed (would be accredited at a favorable rate), poor historical accreditation may have materially harmed the ability of the Market Participants to maintain these offerings with retail customers.

Proposed DSRI Updates and Revisions

                DEI requests MISO quickly implement updates to DSRI in its test environment to allow for higher quality feedback from Market Participants.  Based on the sample screenshot provided as well as some explanation given during the 8/22 RASC meeting, it appears MISO intends to utilize the new "Reduced Load Availability" row to account for load which is simply not present on the system with respect to conditions considered during LMR registration.  In other words, MW values here are differentiated from those listed in the "MWs on Outage" row in that the former represents load which essentially is already "curtailed" from the system due to lower end user consumption at a given time period whereas the latter represents load which is still present on the system, but incapable of being curtailed for some other reason.  DEI requests MISO confirm or clarify this understanding.

LMR Testing Requirements and Compliance / M&V Methodologies

                DEI requests clarity regarding LMR testing requirements, as none (or no changes to historical requirements) appear to be outlined in the proposal.  Given further refinement of LMR accreditation requirements, DEI anticipates further changes to the associated testing requirements of LMRs may also be considered by MISO.  Due to these changes and the aged nature of Attachment TT and associated references to LMR testing criteria, DEI requests MISO review and revise as necessary LMR testing requirements.  Specifically, as applicable to LMRs utilizing a Firm Service Level (FSL; which is likely a commonly utilized Compliance Methodology and does not even have a mention within Attachment TT), MISO should consider compliant testing to reflect an LMR's ability to achieve the registered FSL.

Additionally, given it appears MISO will continue to require a singular (1) test annually, compliant testing criteria should reflect a very likely "misalignment" between the timing of the test and the timing of the hours and conditions reflected in LMR capability quantification calculations performed during LMR registration.  In other words, LMR testing is very likely not to occur during the same conditions used to accredit the LMR and will also not occur in every Season throughout the Planning Year, but once.  Seasonal testing would cause undue burden on end-use customers.  The overall intention of a "curtailment test" needs to be thoughtfully considered, particularly for DR-type LMRs.  As stated above, DEI suggests LMRs utilizing a FSL compliance methodology be able to prove out the ability to achieve the registered FSL during their test, but the literal amount of MW registered should take into consideration different load conditions (i.e.: RA/Tier 2 hours, seasonal peak conditions, etc.) with the MW quantified representing the difference between LMR load(s) at these conditions and the tested FSL.

LMR Notification Time

                In MISO’s proposal, “Emergency” type LMRs have a notification time of 30 minutes.  DEI requests exceptions be granted to allow "Emergency" type LMRs either (60) or (120) minutes of notification time, subject to MISO approval, but otherwise still fully qualifying and still being fully accredited as an "Emergency" type LMR.  Such an approach would be consistent with other RTOs.

                In order to facilitate successful LMR dispatch, Duke stresses the need for MISO to implement automated dispatch instructions and processes.  Having Market Participant operators (i.e.: people) receive messages by e-mail or within the MCS/DSRI, interpret these instructions, and then make decisions on which registrations to dispatch in order to satisfy the instructions will result in end use customers having significantly less than 30-minutes to curtail load.  Given the body of information now available to MISO in its own proposal, MISO should design and implement self-dispatch processes and system, at least in short notification situations (i.e.: less than 2-hours).  Further, MISO should allow MPs to pre-designate priority for dispatch amongst the LMRs if it will continue to request potentially fewer than all available resources during any given dispatch.  For example, some LMRs may consist of utility-owned assets (non-interconnected) which may have a higher priority in the dispatch stack than those LMRs which consist of retail customer assets.

LMR Energy Curtailment Payments

                Duke requests MISO provide energy-based payments for "Emergency" and/or "Non-Emergency" type LMRs in this proposal.  While typically finite in terms of overall value, providing compensation for curtailed energy during emergency dispatch events and/or consideration for compensation during curtailment testing would provide a means to compensate LMRs for energy curtailed and is in alignment with approaches taken in other RTOs.

Short-Term changes Feedback:

IMEA appreciates MISO's efforts to add additional rows in the DSRI tool to accurately determine the availability of the resources. Through this specific feedback IMEA would like to add an additional row that considers the availability subjected to Transmission Owner [69KV & lower] approval or use the existing row as suggested by MISO example as “Reduced load Availability/Available subjected to TO’s approval”.

IMEA maintains a number of these BTMG resources and implements a robust program that involves annual testing and regular maintenance of these resources. A number of these resources are connected to voltage less than 138KV [69KV & 34.5KV] which are not necessarily managed by MISO.  As a result, when the load at the location where the units are connected is lower the availability of these resources is subjected to the Transmission Owners approval to export the resource onto the 69KV and 34.5KV system.

 Traditionally, we have limited the availability in the DSRI based on the actual load limit. Allowing an additional row that will consider additional export capability based on the Transmission Owners approval will reflect the accurate availability of these resources.

Without this adjustment the DSRI data will not reflect the actual availability of these resources to calculate accreditation.

Long-Term changes Feedback:

On the long-term nature of the changes. Can MISO confirm that ICCP is a requirement for all resources including self-scheduling and peaking generators that are interconnected to MISO?

Thank you!

Rakesh Kothakapu

Rkothakapu@imea.org 

VP, Engineering and Markets

IL Municipal Electric Agency 

3400 Conifer Drive I Springfield, IL  62711
o. 217.789.4632  

Wolverine appreciates and supports MISO’s renewed effort to include LMRs as part of its accreditation changes. As shown in the data provided in MISO’s monthly operations reports as well as summary presentations from emergency events such as Winter Storm Elliott, LMRs are historically only available about 50% of the time as compared against their cleared capacity in the Planning Resource Auction (PRA). As the reserve margin tightens, and hence increasing reliability risk, it is vital that accreditation properly be correlated to availability to reduce the reliability risk whereby all resources need to be treated comparably (i.e., not allow LMRs to have easier/less risky requirements to participate in the markets) This is especially true since LMRs are the last resort resources before load shed.

In that light, Wolverine provides the following comments on both the near-term and long-term proposals:

Near-Term Proposal

Wolverine supports the near-term proposal to:

1. improve MISO’s visibility of LMRs by modifying the DSRI tool to provide more data, and
2. to accredit LMRs based on their actual availability during Tier 2 hours.

On its face, MISO’s proposal appears to be a fairly quick solution to implement and therefore Wolverine requests that MISO implement as soon as feasible, ideally for the upcoming 2024/25 PRA but no later than the 25/26 PRA, to ensure that accreditation appropriately aligns with real-time availability for reliability.

Long-Term Proposal

Generally, Wolverine supports MISO’s proposal to treat LMRs comparable to all other resources in the energy market and to truly create a separate emergency only LMR for those resources that do not want to want to participate in the energy market but can respond quick enough to support reliability during an emergency event. The proposal provides MISO better access to resources on a timeline required to meet the reliability needs as well as establishes appropriate market prices. That said, Wolverine provides the following thoughts:

1. Wolverine requests MISO provide further explanation on the Slide 9 bullet from the August 23 RASC presentation - Flag LMRS as only available under certain conditions such as conservative operation and/or warning levels. If the intent is to access LMRs in non-emergency situations, just like all other resources, what is the purpose of having the conservative operations and/or warning level flag? In other words, the bullet appears to say that MISO proposes to still only access non-emergency LMRs during emergency conditions, which is very confusing.
2. Additionally, because the proposal intends to treat “non-emergency” LMRs just like all other resources, MISO’s proposal to include a sliding scale for accreditation based on notification times is unnecessary. There is no sliding scale for accrediting all other non-LMR, non-emergency resources, instead they accredited based on actual availability. Because actual availability is the metric, it is unclear why a sliding scale accreditation based on notification time is also required.
3. For the emergency LMRs (which MISO proposes to have a notification time of no more than 30 minutes), what does MISO propose as a penalty for failure to comply? For example, does the LMR lose revenue from the current year, get banned from participating in future years, receive lower accreditation for the three-year rolling average, or pay some other monetary fine?

Again, Wolverine thanks MISO for the renewed attention to the ensuring all capacity resources have the appropriate and comparable accreditation and looks forward to the continued discussion to implement both the near-term and long-term changes as soon as reasonably feasible, ideally within the next couple PRAs.

Dairyland Power Cooperative – Feedback on the proposed approach for near-term and long-term changes to LMR accreditation

Dairyland Power as a Market Participant for its twenty-four members in four states and its seventeen municipal utilities that both operate and own generation resources, welcomes the opportunity to provide feedback to MISO regarding proposed LMR changes and to inquiry how this could be accomplished.

In its fleet, DPC has over forty diesel generators that provide over 100 MWs of generation capability across its footprint. These units have proven to be reliable sources of generation in the extreme heat of summer, the bitter cold of winter and also when called upon to generate during local transmission limitations. DPC has been diligent in updating the Demand Side Resource Interface (DSRI) tool to ensure MISO is aware of these units’ abilities.

In regard to MISO’s key takeaways, DPC agrees that LMR accreditation should be based on capability and availability of the resource during the periods of highest reliability risk. As such, we do not see a change to require some of the most valuable assets to maintain reliability limited to resources that can respond in 30 minutes. Utilizing the current two-hour notification, LMR units having proven to be a reliable source of energy when needed by MISO. In addition, the current market structure has not shown a need for this product (30-minute availability) as pricing for “Short-Term Reserve” has reflected little value.

If MISO feels that these resources are inaccessible until later stages of system reliability (Energy Emergency Alert 2 (EEA2)), DPC would suggest that MISO look at changing the triggers for access to these resources rather than the start-up time.

DPC would also echo the comments of others regarding defining locations of these resources. Each location of DPC LMRs have defined EP nodes. Utilization of these defined nodes should lend to better knowledge of these resources rather than a zip code.

If MISO persists on insisting on Emergency only LMRs having a maximum start time of 30 minutes, DPC questions if creating a fleet of non-emergency LMRs is even feasible in the MISO market system.

As stated earlier, DPC has over 40 BTMG generators in its system. DPC is also less than ½% of the total MISO system. If there are even ten other Market Participants like DPC, that would mean an additional four hundred units that will be entering the MISO energy market. That would mean on a five-minute basis the MISO system will have to settle an additional four hundred units in its simultaneous feasibility every five minutes. In addition, this will mean an additional four hundred units that will be making entries into the CROW system as a requirement to be compliant with the must offer component of energy offers. This is in comparison to a single entry in the DSRI tool for each MP.

In the August 23^rd presentation, MISO has also asked for ICCP connection for all LMR types. In doing so, MISO has not stated why this is a requirement. The after the fact methodology, though cumbersome, has not limited the reliability these units have afforded. In addition, operationally getting ICCP’s installed would be a challenge. I do not believe DPC would even be able to acquire them in the timeframe laid out for implementation of these changes. At a minimum, we would require at least two years, once any changes are approved, before we could get equipment acquired and installed, if even available. In addition, we would need to know the requirements for doing so. At many sites, we have multiple generators in a single complex. Do we need an ICCP for each generator or each site? Is MISO set up to receive input from and send data to another four hundred generators? To keep a level playing field, will MISO require aggregators to have ICCP at each site, at minimum each zip code? Will MISO be able to distinguish the data coming from an aggregator’s ICCP within an MP LBA when also receiving both load and generator data from the LBA itself.

DPC is not disputing that changes may be required in the LMR system. Our recommendation is that we find ways to keep the most dependable LMRs and the ones that have shown consistent reliability value available. Our recommendation would be to keep the start time at 2 hours and review the stage at which MISO can get access to these needed reliability resources.

A possible risk of not accepting these units as LMRs, is that they may become DRR’s. As such, the MISO system could become less reliable in that as DRRs these units would still qualify towards Resource Adequacy Requirements but are able to “submit offers, set limits, notification times, etc. like other generation resources”.  Meaning a previous LMR resource with a 2 hour, or less, start time needed to maintain 100% accreditation, may now register as a DRR and have as much as a 24 hour start time (like other units), include minimum run times, and still meet requirements. In addition, many of these units may operate on fuel oil and have production costs over $400/MWh. The combination of long start times, minimum run times, and high production and start-up costs, will mean that units would never operate, even in an Emergency situation, and still receive full accreditation because they meet the requirements that MISO has laid out for them.

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 August 23, 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 August 23^rd meeting of the RASC, MISO presented their proposal for near-term and long-term actions on LMR Accreditation. In the near-term, MISO proposes to “utilize Demand Side Resource Interface (DSRI) to leverage availability during defined hours per season” and to “require locational information through the registration/qualification process.” In the long-term, MISO proposes to “redefine and create avenues for LMRs to be accessible prior to emergency conditions (non-emergency LMR)” and establish “emergency-only LMRs (30-minute or less start time) will be need to be highly flexible and reliable.”[3]

MISO requested feedback on the proposed LMR accreditation reforms. AEMA offers the following comments:

• Load Modifying Resources (LMRs): In their presentation, MISO staff stated that LMR accreditation reform is necessary because of a disconnect between planning and operations, a lack of locational information, and the inability of MISO operations to access LMRs without calling an Energy Emergency Alert 2 (EEA2).[4]Although it is understandable that MISO operations would like to see all LMRs respond with the characteristics of a traditional generation or DRR resource, it is important to note that LMRs are critical and valuable resources that support reliable operations of the electric grid. Many of these resources have unique response characteristics and/or operational requirements that prevent them from being as flexible as traditional generation resources or from even participating in DA/RT Markets. MISO should not try to force these resources to become traditional generation resources. Concerns have been repeatedly expressed by MISO and stakeholders that LMRs are only available in emergencies, which is to be expected since many LMRs are historically emergency only resources. Significant modifications to the performance requirements for accreditation must balance enhancing the utilization of the resource and not creating barriers to participation that will cause the resource to withdraw from participation in grid operations. 

• Non-Emergency LMR: AEMA encourages MISO to examine enhancements to the MISO operational systems to accommodate LMR characteristics outside of emergencies. AEMA is opposed to MISO forcing LMRs into existing generation and DRR participation models. Options should exist for LMRs to respond to MISO conditions outside of emergencies, but without being forced to incur the telemetry and/or other technical/logistical barriers of registering as a full DRR. Many resources can respond for more than emergencies but do not currently have a pathway to do so in MISO without becoming a full generation or DRR resource. 

• Near-Term Proposal: In general, the near-term proposal by MISO to utilize average availability during defined hours is aligned with the process that MISO is utilizing for accrediting all other resources. AEMA remains concerned about creating unnecessary barriers to participation for LMRs, by increasing the amount of daily information that is required for reporting of availability; however, the general idea of utilizing the DSRI for accreditation is feasible. While many details need to be defined, the example of the DSRI screen is helpful. The ability to “copy previous day” is useful and MISO should consider enhancing the software so participants can create profile templates that could be automatically loaded for a given day. For instance, a market participant could build a template for full load weekdays, another for weekends, and still another for partial load days. The ability to upload a worksheet that populates the fields would be useful as well.

Additionally, MISO should not exclusively utilize historical data, from before implementation of any new process to drive LMR accreditation because changes to the rules will change how availability is reported. MISO must establish criteria for accreditation, then modify the systems to capture the relevant data before applying to future accreditation with a minimum of one full planning year before applying the data to accreditation. AEMA supports MISO allowing customers to optionally utilize historic performance data at the discretion of the participant, for both accreditation and demonstration of capability. For example, some DR resources may have historically participated in other programs and demonstrated the capability to reliability support the grid. There should be an option to utilize the data from these resources for accreditation. 

In their initial proposal, MISO has noted that it would continue to apply transmission loss and PRM% add back which is an important characteristic to account for in Load Modifying Resources because of their localized position. AEMA supports this provision. 

• Firm Service Level Baseline: As previously expressed in comments on the accreditation of LMRs, AEMA remains concerned about ensuring that customers that can respond to a Firm Service Level (FSL) are able to receive full accreditation. It is not clear how LMRs with FSL will record their availability in the DSLR to ensure that they receive full credit for their availability. If the “self-scheduled” option is used for the difference between peak load and expected load, then the self-scheduled MWs should count as “available” for accreditation purposes.

• Long Term Proposal: In their long-term proposal, MISO has stated that it would separate LMRs into two categories, Non-Emergency and Emergency Only.[5] The Emergency Only LMRs would have a maximum start time of 30 minutes and Non-Emergency LMRs would have a scaled accreditation based upon notification times. Non-Emergency LMRs would be pushed to participate in the Market like other resources. The long-term proposal is problematic. Today, all LMRs are Emergency Only. Resources that can respond as non-emergency resources in the MISO market can register those resources and participate in the market today; however, the current fleet of LMRs has not registered for market participation. Many of the current LMRs are either prohibited from market participation or do not have a sufficient business incentive to incur the costs and ongoing complexities of full market participation. Forcing an LMR into existing market models seems unlikely to produce significant participation, because those resources that can do so are already participating in the existing options for MISO market. This proposal could easily drive some resources out of any participation and the purview of MISO operations which could lead to increased reliability risks to the system.

In the past, AEMA has urged MISO to examine creating a new participation model that bridges the place between emergency only and full market participation. Many consumers are willing to shut down operations during system emergencies, to help prevent cascading blackouts in an uncontrolled manner. There must be incentives for those participants to place themselves as a first line of response during an emergency or pre-emergency. Most participants acknowledge the need for penalties for failure to perform, but the incentives must have a rational economic basis. Currently, MISO has significant penalties for failure to perform during an emergency that other non-emergency resources are not subject to, but little is being done to incentivize giving flexibility for additional capacity from LMRs since existing market models are cost and risk prohibitive. For these reasons, MISO should explore other resource models for supplying capacity and bringing limited market support, ahead of emergencies.

• Emergency Demand Response (EDR): MISO has proposed to eliminate the category of EDR. While this may be feasible MISO must ensure that there is a mechanism for participants to access energy payments for emergencies. While a resource receives a single capacity payment, the risks of multi-day interruptions with no ability to balance cost impact could quickly push resources out of the market. The current EDR option creates an incentive to distinguish ‘last resort’ resources from those other emergency resources that are willing to respond sooner for an economic incentive. Some type of energy response should be available without full market participation.

• Locational Information: MISO has proposed to require detailed locational information on all LMRs. AEMA recognizes the need for locational information to support responses to localized conditions on the system. However, MISO also states that LMRs will be mapped to single EP Nodes, which will prevent aggregation across multiple pricing nodes. As AEMA has stated in the past, this limitation is a significant barrier to participation for aggregators of demand response. MISO should reexamine this proposal and continue to allow aggregation across nodes, even if it is only at a zonal level. Aggregation is a critical participation model strategy for operators of multiple small resources and MISO should continue to allow flexibility in modeling these resources to ensure efficient market participation.  

• ICCP Communications: MISO has suggested that it will consider requiring all LMR types to have an ICCP connection.[6] This requirement is very problematic, particularly for smaller resources. The cost of establishing and maintaining ICCP communications can be high and there is no clearly defined rationale for the ICCP requirements. Currently, LMR resources can provide reliable support for system emergencies without instantaneous ICCP connections and there is no corresponding reliability benefit to adding ICCP connections and their incumbent costs. MISO utilizes LMRs on an infrequent basis, so adding and maintaining ICCP connections for an event that may happen once or twice a year is excessively costly and could push resources out of the market. If MISO operators require additional situational awareness, then folding the current LMR reporting into a bridge model in the DA and RT markets clearing and dispatch engines could be a solution. MISO should examine incorporation of a bridge model into the commitment and dispatch engines that does not require ICCP data. 

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

Voltus Comments to RASC on LMR Accreditation Reforms (RASC-2019-9) (20230822-23)

September 14, 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. 

Proposed Changes to DSRI & Accreditation Based on DSRI Availability Data

Voltus supports the proposed upgrades to the DSRI tool, which would finally provide a single location to manage and track LMR availability, including for resources that dual-enroll as EDRs and/or DRRs. As we have pointed out in previous comments in this proceeding, the current DSRI undercounts availability for LMRs that fulfill their availability requirement through EDR or DRR offers. Accreditation cannot be based on historical data, given the gaps in these data. The new DSRI will need to be in place for at least a full planning year before there is sufficient information to accredit resources based on historical availability data. 

It is impossible to comment fully on the proposal to base accreditation on availability as recorded in the DSRI given current information. We request that MISO provide additional information on how each of the proposed DSRI fields will be defined, and which will count toward availability. MISO needs to also define how LMRs on a Firm Service Level (FSL) baseline are expected to record their availability when they are operating above or below the historical average peak on which their registration volume is based. As Voltus has stated in previous comments, LMR enrollments are based on capability during system peak conditions. For FSL customers, the enrolled amount is the difference between peak load (calculated as described in Business Practice Manual 11) and the FSL or “drop to” load level that an LMR can achieve when dispatched. Real-time operators need to know not just how much reduction they can expect relative to peak conditions, but also how much load drop they can expect to see when they dispatch LMR. If MISO aims to reflect load drop in the availability reported in the DSRI, then reported availability should be based on a standard baseline that measures near-term curtailable load, specifically the so-called “capacity baseline” or “10-of-10 with symmetric multiplicative adjustment.” LMRs on an FSL baseline should report the delta between their peak curtailable load and current curtailable load in the “self scheduled” field of the DSRI. Crucially, the “self scheduled” quantity should count as “available” for accreditation purposes, reflecting the fact that LMRs are accredited based on their curtailment ability during peak conditions. On the supply side, these same resources are included in Planning Reserve Margin Requirements and charged for capacity based on their load at peak demand. As an emergency-only product, LMR is rightfully designed to target peak conditions.

Additionally, Section 69.A.3.5(f) of the Tariff reads: 

There shall be no penalties assessed to a Market Participant representing the entity that has offered ZRCs from the LMR if the Demand Resource is unavailable for interruption as a result of maintenance requirements in accordance with Good Utility Practice, or for reasons of Force Majeure, or in the event that the specified Demand reduction had already been accomplished for other reasons (e.g., economic considerations, operating one’s own Demand Resource at or above the credited level of Demand Resource, or local reliability concerns in accordance with instructions from the Local Balancing Authority).

MISO therefore needs to define where in the new DSRI MPs would record LMR unavailability that falls under the categories permitted by the Tariff. 

The mock up of the new DSRI shows “DRR Type I Offered MWs”. This row should be relabeled as “DRR Offered MW”, and should also account for any MW offered via the DRR Type II resource type. Both the DRR and EDR availability values should be filled in automatically by MISO, rather than by Market Participants, by directly pulling from the EDR and DRR offer submissions submitted in other parts of the MISO portal (namely the EDR Offer Submission Tool and the DRR Market User Interface). 

Locational information

Voltus has no objection to the proposal to require detailed location information for all enrolled LMRs. In fact, aggregators like Voltus are already required to provide full addresses for all locations behind our LMRs. We are surprised to learn that other Market Participants enrolling LMRs are not subject to equal requirements and request that MISO clarify the requirements for the upcoming enrollment period such that all LMRs have the same requirements. 

Voltus strongly objects to the implication that LMRs in the future will be mapped to EP Nodes, and therefore aggregations will be limited to EP Nodes, unless performance aggregation will be calculated across LMR resources. As of today, performance calculations are performed for each individual LMR resource; MISO does not aggregate performance across resources.The level of aggregation allowed at the time of enrollment therefore determines the level of aggregation at the time of performance measurement and verification. By limiting resources to a single EP Node, MISO would be effectively eliminating aggregation. If MISO wishes that resource mapping occurs at the EP Node, then additional performance aggregation language needs to be added.  

Aggregation is essential for operators of many small assets, in order to balance the inevitability that many small assets will provide a mix of over- and under-performance during dispatches. Performance is more predictable at the aggregate level than at the individual location level. As Voltus has stated in an open Issue Submission, MISO should limit the scope of aggregations at the time of enrollment only if they then calculate LMR performance in aggregate at the level at which the LMR program is called. For example, if all of a Market Participant’s LMRs across an LBA are dispatched, performance should be calculated in aggregate across all LMRs within that LBA. This performance measurement would measure what relief the MP provided to the LBA that was facing an emergency.  If an emergency occurs across a Resource Zone, and all of the LMRs in that Resource Zone are deployed, the aggregate contribution of the LMRs in that Resource Zone should be what is measured. There are numerous precedents to this proposed format, including PJM’s Load Management emergency capacity program, in which performance for all of a market participant’s Demand Resources across the entire Emergency Action Area (EAA) are aggregated when measuring that participant’s compliance.

The proposal to limit aggregation to EP Nodes would reduce the amount of LMR that is able to participate in the MISO market, thus reducing supply availability, increasing pricing, and reducing reliability. 

Long term proposal

Voltus is generally supportive of the proposal to bifurcate LMRs into Non-Emergency and Emergency Only categories, but only once the following topics are addressed:

• LMRs must have a way to receive energy payments when dispatched. We ask that MISO clarify why they are proposing to eliminate EDR dual enrollment and how instead resources will receive these payments. 

• We ask that MISO clarify how the Non-Emergency LMR proposal is different from the current state of affairs where DRRs can earn capacity credit, and if there will be any changes to how DRRs may earn capacity credit. 

• The enrollment process needs to be more, not less, streamlined. The proposal for Non-Emergency LMRs to manage their availability through DRR offers will only be feasible if there is a new single enrollment process. Currently, the LMR and DRR enrollment process are very different from one another and dual enrollment is administratively burdensome for all stakeholders including aggregators, LSEs, RERRAs, LBAs, and MISO staff. 

• Please clarify if accreditation for Non-Emergency LMRs would be based only on notification time in the long term proposal, or if it would be based also on availability data as recorded in the DSRI (and if both, how?). MISO should clarify how accreditation would use DSRI data to accredit Non-Emergency vs. Emergency Only LMRs. 

• MISO rules must treat demand response equitably with other supply-side resources. Accreditation should only scale with notification time for demand response if the same is true of generators.

The proposed requirements for capacity accreditation for Non-Emergency LMRs should be treated as a floor, not a ceiling, for what demand resources can provide. For example, the proposal states that Non-Emergency LMRs should only “be available under certain conditions such as conservative operations and/or warning levels”. Non-Emergency LMRs should retain the option to offer in economically or by self scheduling for ancillary services or energy, even outside of tight margin hours. 

Respectfully submitted,

Emily Orvis

Vice President of Energy Markets

Voltus, Inc.

Alcoa Power Generating, Inc. (APGI)

Feedback on

“LMR Accreditation (RASC-2019-9) (20230822-23)”

September 14, 2023

During the August 23, 2022, 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:

• Near-Term Proposal: APGI has no issues with the general concept of MISO’s near-term proposal to “utilize Demand Side Resource Interface (DSRI) to leverage availability during defined hours per season.” However, as a user of the DSRI, APGI would point out that the overall design of the DSRI remains awkward and inefficient for participants like APGI. For example, APGI has BTMG resources that provide hourly updates of availability in the DSRI. Like many industrial consumers, APGI utilizes their BTMGs to serve their demand. APGI’s co-generation BTMGs are generally self-scheduled when MISO LMP is above APGI’s cost of generation. Often, the DSRI shows the units as self-scheduled and fully deployed to their available capacity. This makes it appear that there is nothing “available” for MISO operations and the daily updates add no value to the overall emergency process. MISO should develop other mechanisms for these types of resources to report status, perhaps simply using the MISO CROW, that removes non-value adding work processes such as updating the daily DSRI.

Because of the size of the APGI BTMG, these resources are also reported in the MISO CROW and have GADS reporting requirements. Because of the limited MISO options for registration of resources, APGI has no mechanism to signal the status of these generators in the DA and RT markets. It is APGI’s perspective that more efficient processes should be explored that give MISO RT operations better insight into these resources and allow them to schedule into the DA/RT markets. This could be done by shifting status into the DART portal without forcing market participants to transition these types of resources into full market resources.   

• Transmission Losses and PRM Add Back: In their proposal, MISO states that they will continue to add back transmission losses and PRM for LMRs because LMRs are directly at the point of the customer. APGI is a real-world consumer with BTMG that can fully cover the load being served. The application of transmission system losses or additional reserves would be inappropriate for the APGI load served and other, similarly configured resources because there is often no net load on the MISO system during full BTMG deployment. APGI supports MISO continuing with this proposed design element.

• Long-Term Proposal: In the long-term, MISO proposes to split LMRs into Non-Emergency and Emergency Only resources. APGI would support other commentors who have encouraged MISO not to redefine LMR, but to explore an alternative registration option that could motivate existing LMRs to transition to a status in between DA/RT participation and emergency only. Emergency only resources have a critical role and function in reliable system operations and the emergency only option should remain open to consumers.

Widespread, uncontrolled outages can be much more disruptive than controlled shutdowns, especially to the operational processes of many large industrial consumers like APGI. Many industrial consumers like APGI would prefer taking a planned interruption to an unscheduled interruption, but only in the event of extreme system emergency, just prior to system blackout. APGI has a long history of supporting grid reliability, through the occasional interruption of loads and the option should remain available to consumers like APGI.

An example of a bridge resource might be a non-emergency LMR that can be price sensitive and activated at an earlier stage of capacity shortages but is entered into the DART portal. These resources would receive energy compensation if deployed.

• ICCP Communications: MISO has suggested that it will require ICCP connection from all LMRs in the long-term proposal. AGPI requests that MISO reconsidered this costly change, which would provide no additional reliability benefit. Currently, APGI operates its BTMG in a manner to support economic and reliable grid operations. The addition of ICCP communications and the associated metering/telecommunications systems would add no additional value to system operations. APGI urges MISO to examine other processes that can achieve operational awareness without the installation of ICCP connections and related data.

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

Steve.Dowell1@alcoa.com  

DeWayne Todd

DDT LLC

(812) 573-8052

dewayne.todd1@alcoa.com

GRE supports the LMR accreditation changes that link the capacity value awarded to the LMR more closely to the availability of the resource during periods of highest reliability risk. This matches the recent evolutions MISO has made to Schedule 53 resources and the new SAC calculations introduced for PY 2023/24, and this puts LMR’s in the same playing field for evaluating true value during times of true reliability need.

Near-Term: DSRI Enhancements and LMR Accreditation (New Intermittent BTMG DSRI requirement)

In MISO’s 20230822-23 RASC Item 09biii LMR Accreditation (RASC-2019-9) presentation, slide 5 shows that Intermittent BTMG will have a new requirement to provide hourly data to the Demand Side Resource Interface to allow the operators to leverage this resources availability during emergencies.  Echoing verbal comments from the October 2022 and January 2023 RASC meetings, GRE finds this new requirement overly cumbersome for market participants and doesn’t improve operator visibility to available assets for Intermittent BTMG’s which are constantly self-scheduled and always generating energy when the sun/wind is available. In these cases, these retail-connected BTMG’s have an incentive to always be must-running, regardless of market conditions and are thus going to be continuously “self scheduled” in the DSRI tool. Furthermore, the precise amount of MW that these intermittent BTMG’s will produce will be cumbersome to forecast and anticipate in the DSRI availability menu’s, since the kW’s produced depend on local weather conditions like cloud cover & wind speed. Many of these retail-connected intermittent BTMG’s are thus not truly available for MISO operators dispatch, because they are already fully operating and there will never be any additional MW available to MISO because the generators are already maxing out their full potential to the distribution grid.

Requiring LBA’s to report self-scheduled intermittent generator output 24/7 365 days a year will provide no added visibility or accessibility to MISO operators to efficiently manage the grid during times of need, and only adds a reporting burden to balancing authority operators to provide meaningless data to MISO.

Near-Term: DSRI Enhancements and LMR Accreditation (New EP Node/Zipcode identification requirement)

MISO introduced new qualification requirements for Load Modifying Resources in the BPM-011-r29 Redline document posted on August 23, 2023. In section 4.2.6, BTMG’s are now proposed to be required to submit the zip code of the physical location of all generators in the BTMG registration. In Section 4.2.7, Demand Resources (DR’s) are now proposed to be required to submit the zip code for every physical location of the asset in the DR registration.

This new requirement for BTMG and DR seems illogical and unsupported by MISO presentation materials and stakeholder discussions. I understand that MISO wants visibility into the electrical location of the LMR’s to improve operator ability to manage localized transmission emergencies. But requiring the zip code does not lead BA operators to the correct mapping or knowledge of electrical location in the system for reliability operators to effectively manage Transmission System Emergencies or Local Transmission Emergencies. If local connection knowledge is what MISO seeks, require the EP node rather than the US Postal Service mail delivery area. For rural electric cooperatives, in many cases the zip code doesn’t clearly distinguish whether the load is served by the local cooperative’s distribution substation EP Node, or if the load is served by a nearby municipality or township with the same zipcode using a different EP Node.

Near-Term: DSRI Enhancements and LMR Accreditation (New Zip Code Aggregation Boundary)

In Section 4.2.6 of the BPM-011-r29, it's also surprising to see MISO suggesting that BTMG's cannot be aggregated from within a single CP Node (as is today), but instead can only be aggregated from within a zip code. This new requirement would break up potentially large aggregations of dozens of smaller assts into smaller LMR-BTMG's, some of which now may not meet the 100kW threshold.

This also contradicts the discussion and posted Meeting Minutes of the January 17-18, 2023 meeting item 10, which states that "MISO intends to collect the EP Node for all LMRs within a group but will not require groups to be registered for each EPNode".

GRE objects to this new proposed draft BPM language which introduces a requirement to limit registration groups according to each zip code (sic EP Node). MISO hasn't demonstrated why this new boundary restriction for aggregation candidates is necessary or warranted.

Transmission Losses and PRM% add back:

In MISO’s 20230822-23 RASC Item 09biii LMR Accreditation (RASC-2019-9) presentation, slide 8 shows that the Accreditation Calculation will acknowledge Transmission Losses and PRM % add back variables when calculating LMR accreditation value.

Currently, MISO Tariff section 68A.8 Module E-1 page 16 states that BTMG, DEAR, DR and EER should be grossed up by the transmission loss percentage. Section 69A.3.2 pg 58 (for EE), and 69A.3.3 (for DR) states that the resource will also be grossed-up by the applicable PRM in accordance with Section 68.A.2 in addition to the transmission loss percentage. However, Section 69A.3.3 (BTMG) states that the BTMG's will only receive the transmission loss percentage gross up.

This appears to be an inconsistency in the accreditation value of customer-sited assets, and demonstrates unequal treatment of LMR's between LMR-DR and LMR-BTMG's. This would be a good time to reconcile what must have been an oversight in the disparity between grossing up PRM % values for Demand Resources but not for BTMG’s. GRE would like MISO to clarify in future proposals that this design element intends to preserve the existing treatment of LMR-DR’s but also specifically introduces the PRM % add back for LMR-BTMG’s. This requires a tariff revision to section 69A.3.3.

Longterm Strawman

Please explain better the intent that MISO stated verbally. To paraphrase the verbal discussion, MISO statued there would not be a new construct introduced called “Non-emergency LMR’s”, but rather that any resources with a notification time greater than 30 minutes would simply cease to be qualifiable as LMRs and instead would need to be registered as DRR Type-I’s and have appropriate startup times defined along with Market offer parameters. This was the nature of MISO verbal comments, but GRE would like to confirm if this was MISO’s intent in the strawman proposal. This clarification is needed before GRE can weigh in on the merits of the proposal.

MISO is suggesting that both LMR types will be required to have an ICCP connection – GRE requests that MISO confirms that this connection is required at the aggregator operator level, not at each individual physical location.