RASC: BPM-011 Redlines (20240821)

RASC: BPM-011 Redlines (20240821) Alliant Energy Feedback

1. ACP Determination:
• It seems the Auction Clearing Price (ACP) will be influenced by a combination of the subregional RBDC and regional RBDC curves. How exactly will this be implemented in the auction process?
• Is there a specific weighting or method for combining these in the auction?
2. Impact of DLOL on RBDC:
• How would Distributed Loss of Load (DLOL) affect the RBDC calculation? Will it change the value or shape of the RBDC curves?
3. Monte Carlo Simulations and RBDC:
• How will the Monte Carlo analysis impact the RBDC curves? Is this mainly a forward-looking tool to help identify potential shortfalls and notify LSEs in advance, or does it directly influence the current RBDC process?
• Does this forward look include the transmission upgrades in the MISO tranches?
4. FRAP and Replacement Capacity:
• Can an LSE use extra capacity they designated through FRAP as replacement capacity if the LSE FRAPs more capacity than the Final PRMR?
• Does the LSE receive compensation for any excess capacity provided by FRAPing over their Final PRMR?
• If an LSE FRAPs up to their Initial PRMR but needs to purchase additional capacity to meet their Final PRMR, will the price for that additional capacity be determined by the Auction Clearing Price (ACP)?

Clean-up request for BPM-011 from a series of questions/feedback I received from an inquiry submitted to help@misoenergy.com in August regarding Run-of-River Hydro accreditation.  The language of sections 4.2.1.6, 4.2.1.3, and Appendix V is inconsistent.  The feedback received clarified run-of-river hydro is accredited based on up to 15 years of historical production, not the past 3 years of each each season (9 months total).  The existing language in the BPM incorrectly intermixes run-of-river hydro accreditation with solar accreditation and should be corrected.  These changes were not made to the r30 version of the BPM-011.

The OMS Resources Work Group (RWG) provides this feedback to MISO in response to its proposed redlines to BPM-011 Resource Adequacy. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors. 

Please clarify whether the date when RERRAs must provide an objection to an LSE opt-out could be before February 17, 2025, in a situation where MISO provides RERRAs with notification sooner than the allowed five business days after the LSE opt-out deadline. 

• The BPM redlines provide the February 17 date but also state that “MISO as Transmission Provider will verify the information and notify the RERRA within five (5) business days following deadline of the LSEs initial submission. RERRA has up to twenty (20) business days to notify MISO its decision.” This provision suggests that if MISO gives RERRAs notice earlier than five days, the RERRA deadline would also shift.

The RWG requests MISO clarify in the BPM that when RERRAs get notification that an LSE is requesting to opt-out, the RERRA also receives the associated LSE opt-out plan.

The RWG recommends that MISO add annotations and context for the example of the RBDC clearing scenario that is provided. Additional context would help with interpretation.