In the February 28 - March 1 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were asked to provide feedback on the usefulness of the Out-Year Capacity Import/Capacity Export Limit Study.
Comments are requested by March 31, 2023.
MidAmerican appreciates the opportunity to provide feedback on the usefulness of the Out-Year Capacity Import/Capacity Export Limit Study. (20230228-0301).
CIL and CEL studies could be included in the Regional Resource Assessment study process instead of being a part of the annual capacity auction updates, but MISO should not discontinue forecasts of future CIL and CEL values.
The out-year CIL and CEL results were initially requested by stakeholders to provide information to market participants as the CIL and CEL changed during the construction of the MISO Multi-Value Projects (MVPs).
Similar to the MVP transition, development of out-year CIL and CEL values will continue to provide important information to market participants and should be regularly updated as the resource transition continues. MISO should modify the current analysis to analyze how CIL and CEL change as Long-Range Transmission Plan Tranche 1 projects are constructed. For example, one future year prior to the LRTP Tranche 1 projects going into service should be studied and CIL and CEL values produced. Similarly, and one future year following construction of LRTP Tranche 1 projects should be studied and CIL and CEL values produced. This will provide information that market participants can utilize to aid in analyses of future market conditions.
MidAmerican urges MISO to continue to provide this valuable information to MISO market participants.
Xcel Energy appreciates the opportunity to provide feedback regarding Out-Year CIL CEL results. We believe Out-Year UCAP/ISAC ratios would be more beneficial to our expansion plan modeling than CIL CEL values. If MISO would commit to providing the Out-Year UCAP/ISAC ratios, we could support elimination of the Out Year CIL CEL analysis.
DTE appreciates the ability to provide feedback on the out-year CIL/CEL study. DTE has used the Out-Year CIL CEL results in the past, but due to the volatility in the forecast it is no longer used. DTE is okay with MISO discontinuing the forecast.
WEC Energy Group utilizes the out-year CIL and CEL studies to ensure the zonal resource plan contains sufficient resources to meet the Local Clearing Requirement (LCR). In particular, we look for out-year CIL and CEL values to remain constant or increase in comparison to the prompt year values. Significant decreases in out-year CIL values increase the LCR and could result in insufficient local resources, signaling the need to build local or increase the zonal import capability. Significant decreases in CEL affect the viability of resources external to the Local Resource Zone to meet the PRMR and could result in unhedgeable price separation.
WEC Energy Group is also aware that out-year CIL and CEL values are indicative only and appropriately weights the out-year information when making assessments.