RASC: LMR Accreditation Draft Tariff (RASC-2019-9)

WPPI provides below initial comments on the posted Module E-1 revisions and Schedule 53B draft.  These represent our initial reactions to those document drafts only, and we will add any further comments on the posted documents by December 9.  We note many issues in the two draft documents, which we expect will need significant further stakeholder review to respond to any changes that MISO makes based on initial comments.

Module E-1

1. MISO’s use of the term Tolerance Band in the proposed changes to Module E-1, and in Schedule 53B, is problematic.  Under the existing tariff, this term means the range outside of which Excessive and Deficient Energy may be calculated.  Tolerance Band calculations for DRRs are already specified in the tariff at 40.3.4 and should not be redefined elsewhere in the tariff, as this introduces the potential for inconsistent definitions (and, indeed, 40.3.4.a.1 appears inconsistent with both 69A.3.5.e and Schedule 53B.1.A.9).  Instead, where Tolerance Band is used outside of 40.3.4, such as DRR testing or accreditation, reference should be made to 40.3.4.  69A.3.5.e, in particular, is problematic as it appears to refer to an entirely different type of tolerance band—based on Firm Service Level rather than MISO instruction—than is used in 40.3.4.
2. 69A.3.1.h refers to a “Planning Resource that is disqualified due to a complete failure to perform as defined in Section 69A.3.9.”  Disqualification, however, is never referred to with that name in 69A.3.9, but rather only in 69A.3.8, pertaining to testing.  And while 69A.3.9 refers to a loss of eligibility for status as a Planning Resource (which sounds like disqualification, but should be specifically named as such if that is MISO’s intent) this pertains only to a resource that experiences a second complete failure to perform within a three-Planning-Year period.  MISO should clarify what specific disqualification provisions it is referring to within 69A.3.1.h and refrain from characterizing these circumstances in a way that is at variance with how they are described in either 69A.3.8 or 69A.3.9, as relevant.
3. 69A.3.5 purports to concern Demand Resource eligibility, but includes provisions that go far beyond applicability to eligibility, to include performance requirements and exposure to penalties, which are also discussed elsewhere.  Please carefully review the entire set of proposed revisions—and relevant parts of the existing Module E-1, to ensure that rule provisions are presented exactly once, and in the appropriate location.
   1. For example, 69A.3.5.e describes a 10% “Tolerance Band” that is to be applied “when determining if a resource has deployed to or below its Firm Service Level.”  This appears to be a description of a performance criterion, and not an eligibility requirement,  If that is indeed MISO’s intent, we suggest moving this to 69A.3.9, which could logically cover performance requirements and penalties.
   2. 69A.3.5.j provides that resources “that neither conduct a real power test nor meet Scheduling Instructions issued by the Transmission Provider during the prior Planning Year must participate in training provided by the Transmission Provider on the deployment of LMRs during the prior Planning Year.”  This appears to be best characterized as a testing provision to be included in 69A.3.8 rather than an initial eligibility provision.  We would also suggest that the timing described here is flawed, and that the timing of the requirement to participate in training should be arranged such that the required training occurs after—rather than within—the Planning Year for which the testing or scheduling-instruction response criteria are being evaluated.  Please reconsider the timing described here. 
4. Broadly speaking, the same problems appear in 69A.3.6, where provisions related to BTMG performance requirements or penalties, such as  69A.3.6.g, are included in the eligibility section rather than a separate section on performance requirements and penalties.
5. 69A.3.8.1 makes what appears to be a unique reference to resources “enrolled in the PRA.”  This terminology appears incorrect to us, as enrollment and PRA participation—while obviously linked in most cases—are distinct processes, and enrollment does not necessarily imply PRA participation.  We suggest, as alternatives, “enrolled for capacity” or “enrolled for resource adequacy.”
6. 69A.3.8.1 describes criteria for passing a test as a response “consistent with the enrolled response time and stated Capacity Availability” without reference to the duration of the response.  If MISO intends that a duration requirement also apply, that needs to be specified.  We stress that it would appear unreasonable to apply a duration requirement to Direct Verification Demand Resources not reliant on BTMG, as there would be no basis to believe that interruption could not, as a technical matter, be maintained indefinitely.  To the extent that BTMG demonstrate ability to perform for four hours in a GVTC test, there is similarly no apparent basis to require any particular duration in a separate MISO-directed test, whose only purpose would appear to be to confirm response within the enrolled response time.  In any case, we ask MISO to clarify its intent around test duration requirements.
7. 69A.3.8.3 states that “A test will be deemed to have been fully passed if the resource being tested is able to achieve its stated Capacity Availability within its enrolled response time and deploy to or below its Firm Service Level.”  This appears at least potentially inconsistent with the description on 69A.3.8.1 that refers to stated Capacity Availability rather than Firm Service Level.  We ask MISO to reconcile these descriptions and provide a single clear standard.
8. 69a.3.8.4 describes test failures and penalties.  Any ACP-based penalty calculation must specify both the MW quantity and the number of days to be multiplied by the $/MW*day ACP.  MISO does not specify the number of days in this section.  In addition MISO includes a qualifier “until the retest is performed” in the description.  This requires more explanation around, at a minimum, whether a penalty applies only to the days prior to a retest, or whether a penalty is refundable after a re-test.  
9. 69.A.3.8.5 says that “Two tests failures in the same Planning Year count towards determining whether a resource shall be disqualified for three (3) Planning Years.”  MISO needs to specify what the test-failure criterion is that two failures within the same Planning Year count towards.
10. 69A.3.9.a provides for penalties where “the DRR or LMR is called upon during an Emergency as declared by the Transmission Provider and the DRR or LMR fails to perform in accordance with its Market Participant’s response to such Market Participant’s Setpoint Instructions or Scheduling Instructions.” 
    1. We find this to be very unclear language, and we recommend that MISO delete “Market Participant’s response to such” from the sentence.
    2. MISO should specify that LMR overperformance when called upon during an emergency will not be subject to penalty.
11. 69A.3.9 describes penalties that apply equally to DR and BTMG resources.  BTMG are generators that are subject to both required maintenance outages and forced outages, like any other generator.  For any generator, outage propensity should be reflected in accreditation, and not in draconian penalties for nonperformance.  This is a substantial and fundamental problem.
12. 69A.3.9.b describes consequences of a complete failure to perform.  Several issues appear in this section.
    1. Complete failure is described as timely providing less than 50% of stated Capacity Availability, but this paragraph notes that performance “shall always be measured using the appropriate consumption baseline specified at enrollment.”  Stated Capacity Availability, however, is not calculated with respect to any baseline.  Accordingly, these provisions require revision or further explanation.
    2. Three different conditions, i) through iii), are included near the end of the paragraph.  Both i) and iii) appear to pertain to the case of ZRC Replacement, whereas ii) does not.  At a minimum, for the sake of clarity, we would suggest keeping i) and iii) together, preferably by switching i) and ii).  
    3. Condition i) describes the need for an immediate test of “the resource.”  Based on the language in part iii), we presume that the resource in question is the replacement resource.  We would ask MISO to clarify this.
    4. It appears illogical to require immediate test of a replacement resource, which would typically have no particular connection to the non-performing resource.  All that should be required of the replacement resource is that it be an enrolled resource that has met all the previous testing or other requirements to maintain its current enrollment.  Accordingly, this section should refer only to the Replacement requirement, and the CRNCC that would apply in the absence of replacement, with no discussion of a testing requirement.
13. 69A.3.9.b refers to a distribution of CRNCC charges at variance with the provisions of 3.1.h.b.  We suggest that, for the sake of clarity, MISO leave all description of CRNCC distribution in 3.1.h.b and make additions or revisions to that section as necessary to account for differential treatment MISO proposes for collections from non-performing LMRs, and not have facially contradictory provisions in different sections of the tariff.
14. 69A.3.9.e refers to “Hours covered by Schedule 53B.”  We presume that MISO means to refer to Capacity At Risk Hours and RA Hours, but if so MISO should say this explicitly since other hours are referred to in that draft schedule.

Schedule 53B

15. MISO should avoid use of the expression “Tier 2 Seasonal RA Hours.”  At a minimum, this is redundant as it means the same thing as “Seasonal RA Hours,” which is defined in Schedule 53A.  It also appears improper, as we believe there is no definition of “Tier 2 Hours” anywhere in the tariff (though there is a single reference to this term in Schedule 53A).  Tier 1 and Tier 2 describe ISAC calculations, and underlying outage exemptions, but not Hours.  Please consider removing “Tier 2” everywhere this expression is used in Schedule 53B.
16. Our understanding is that there may be overlap between RA Hours and Capacity At Risk Hours.  Accordingly, it is technically incorrect to refer to the sum of the two sets of hours when what MISO really wants is the total number of hours that meet the criteria for at least one of these categories.  Accordingly, rather than referring, for example, to “the sum of the number of Capacity At Risk Hours and number of Tier 2 Seasonal RA Hours in a Season,” MISO should refer to the number of hours in a season that are either Capacity At Risk Hours or RA Hours.
17. The proposed definition of Seasonal Emergency Hour Deficiency is incoherent.  As written, it appears to define this term as: i) a season; ii) a value calculated subtracting the number of Capacity At Risk and RA Hours from 65; and iii) the state of having fewer than 65 Capacity At Risk and RA Hours in a season.  The proper definition would appear to be as follows:

1. 1. The positive difference between 65 and the number of Hours in a Season that are either Capacity At Risk Hours or RA Hours.

18. MISO’s description of the Tolerance Band calculation is incoherent.  MISO refers to excessive and deficient Capacity Availability in terms of total percentages (112% and 88%, respectively), but then makes corresponding references to MW quantities that do not make sense in terms of total values.  Instead, based on 40.3.4, the MW quantities cited appear to be possible references to the tolerated 12% deviation, rather than the total 112% and 88% quantities.  Consider, for example, that it would be absurd to set the excessive Capacity Availability, as defined, for a 40 MW DR at 30 MW, or for a 9 MW DR at 1 MW, which is the plain meaning of the draft tariff language.  Moreover, while we recognize that MISO has drawn on 40.3.4 in developing this language, we suggest that MISO reconsider these numbers such that the tolerance band is at least continuous across DR size classes, e.g. so that a tolerance of 12% for a 10 MW DR (1.2 MW) matches the “not less than six … MW” for resources incrementally larger than 10 MW. 
19. Three times in the draft MISO says that “There shall be no weights applied to hourly capability values in accreditation.  What MISO means to say here presumably is that equal weights will be applied, not that no weights will be applied (which is a technically incorrect statement).  Moreover, this is completely superfluous as the (equal-weighting) calculation is already specified in detail in the draft.  Please consider—at a minimum—revising and—preferably—removing altogether.
20.  In describing how Capability will be calculated, MISO notes that Self Scheduled demand response will be reflected in the Capability calculation provided that it occurs “during a Capacity At Risk Hour and that the Load reduction was maintained for at least four … hours.”  There is no obvious reason to require the self-schedule be maintained for four hours, and this makes no sense in the case where Capacity At Risk hours may not last four hours beyond initiation of a self schedule, or even occur in contiguous four-hour blocks in some cases.  Moreover, this restriction that self-scheduled demand reductions only be considered during Capacity At Risk Hours will fail to account for demand reductions that may be driven by abnormally high LMP levels outside of a Capacity At Risk Hour.  This poses a risk of misalignment between resource accreditation and allocation of PRMR to the extent that such self-scheduling results in reduced accreditation but not reduction on PRMR allocation.
21. Please consider improvements to the equations in the draft.  For sums involving H hourly Capability values, consider specifying that the sum is over h between 1 and H, as shown for N in the equation in III.B.2.c.  Also, where hyphenated terms are used, please ensure that these are properly formatted a hyphenated terms and not rendered as subtraction operations that use spaces and an en-dash.  This can be done as described here: https://superuser.com/questions/1305601/how-to-insert-a-hyphen-in-microsoft-equations-instead-of-a-minus-sign.
22. We note that Tolerance Band a defined term in Module A pertaining to the calculation of Excessive and Deficient Energy.  We understand that MISO wants to make use of this calculated quantity for the additional distinct purpose of accreditation calculations.  We advise MISO to take care to avoid confusion in re-using this term as part of a new definition.  Our suggestion would be to reduce potential confusion by eliminating this term entirely from Schedule 53B, given that it appears entirely unnecessary since the terms Excessive Capacity Availability and Deficient Capacity Availability are already introduced in Schedule 53B and these should be wholly sufficient to describe the accreditation provisions in question.
23. Section V concerns what are described as penalty provisions for DRRs and LMRs, but that appear to be nothing more than a reiteration of the accreditation provisions described at III.B.2.b.  This is unnecessarily confusing.  Please either remove this section or describe how it is distinct from the provisions of III.B.2.b. 

ABATE, IIEC, LEUG, TIEC, CMTC, MLEC and MIC, as representatives of the Eligible End-Use Customer (EUC) Sector, and NLCG have submitted comments in PDF format to MISO Stakeholder Relations.  The comments should appear posted under Supplemental Stakeholder Feedback once Stakeholder Relations has an opportunity to post them there.  

Duke Energy provides the following additional comments and feedback in response to MISO's RASC: LMR Accreditation Draft Tariff (RASC-2019-9)  

“The DRRs will be able to continue to participate in the PRA. The Tariff changes propose to redefine a DRR to be a Planning Resource rather than a Capacity Resource and thus remove the Day Ahead must offer obligation.” (MISO’s RASC: LMR Accreditation Draft Tariff (RASC-2019-9)

• Duke Energy supports MISO’s proposed Tariff Changes to redefine a DRR to be a Planning Resource rather than a Capacity Resource and thus remove the Day Ahead must offer obligation.

See attached documents.

CMPAS appreciates the opportunity to submit comments on LMR Reforms. These comments focus on specific tariff redlines and supplement what we submitted on December 4 regarding LMR Reform (RASC-2019-9) (20241106).

Comment on Schedule 53B Tariff Redlines: 

1. Schedule 53B, Section II. “Resource Class Mapping” indicates that the Resource Classes set forth in Schedule 53A will be used to map Schedule 53B resources.  Which Resource Class would a BTMG fueled by landfill gas be counted under? Can language be added about what happens in the event there is a BTMG that is not covered in one of the Schedule 53A Resource Classes?

2. Schedule 53B, Section III. “Accreditation of Schedule 53B Resources”, C. Behind the Meter Generation – Load Modifying Resources/Demand Response Resources, 2. Capability, parts a. and b.  The way this definition is written, it suggests that Capability calculations are binary and mutually exclusive: either a resource is generating, or it’s not, and Capability follows from the operational status or data submitted by the BTMG.  This definition ignores a third way in which Capability is determined: MISO adjusting Capability, as noted in the LMR Whitepaper Version 2.0. Please see the “Example 2” on pages 20 in the LMR Whitepaper Version 2.0 released on November. In this case, the value of Capability for the resource with the 4.5 hour response is set to zero for a specific event, regardless of whether the resource submits data that it is available. As such, the Capability status for this BTMG is not based on (a) or (b) as written in the draft Schedule 53B definition of Capability, but rather MISO’s own, exogenous adjustment of Capability as described in Example 2 of the LMR Whitepaper. Please add a “part c” to this Capability definition in Section of 53B indicating that Capability can also be directly calculated by MISO, who will set Capability calculations to zero in certain circumstances based on event type and participation model used by a resource.

Please see email attachments for GRE comments and edits to the posted Tariff sections of Attachment TT, Schedule 53B, and Module E-1.

DTE appreciates the opportunity to provide feedback on the LMR reform draft tariff language.

Attachment TT:

Statistical Interval Baseline

                                In section 3.d.i, DTE believes that sampling once every month is unnecessary as it is cost prohibitive, time intensive, and the additional value gained from resampling as often as one month is not beneficial.  Instead, DTE proposes that the tariff language be updated to require four different samples to be developed (1 for each season), and that the sample be refreshed once every three years unless the Market Participant observes a large change in population requiring the sample to be refreshed earlier.

Meter Data Requirements

DTE requests that the Meter Data requirements section of Attachment TT be updated to align with the Audit Rights section of the Module C tariff. Common language should specify the granularity of reporting requirements, such as hourly or 30-minute increments, as well as the level of aggregation, whether it should be at the customer level or program level.

As MISO is determining the data reporting and retention requirements, DTE recommends no more granular than 30-minute intervals and to limit retention to 18 months of history.  Any requirement above 18 months would require significant investment and processing capabilities added.

To provide context, DTE has AMI fully deployed within its service territory. Currently, 30-minute data is available for its Commercial and Industrial (C and I) and 60-minute data is available for its residential and commercial secondary customers. The AMI meter is capable of providing 30-minute intervals for residential customers, but this functionality has not been turned on for all AMI meters due to the IT infrastructure required to collect the massive amount of data. Simply put, there is not enough bandwidth on the system to be able to transmit and store this amount of data.

To expand further, DTE has nearly 350,000 residential customers that participate in DR programs. Collecting 30-minute intervals for this amount of customers would total 6.1 billion data points in a single year. This value can be cut in half if 60-minute intervals suffice but would double if 15-minute intervals became the requirement. Furthermore, because of how residential customers enroll and unenroll in these programs, 30-minute functionality would have to be turned on for all residential customers to assure 30-minute data is available for all participating customers in a DR program. DTE serves 1.9 million residential customers. One year of 30-minute intervals would total 32.8 billion data points. Processing this amount of data on an annual basis and potentially adding new technology to enable the collection of this data would likely be cost prohibitive to DTE and other MISO participants.

To limit the amount of data processing and storage, DTE recommends MISO allow meter data submissions for residential demand response programs to follow the sampling methodology described in the Statistical Interval Baseline section of attachment TT with the sampling adjustments DTE has proposed.

Additionally, If MISO requires more granular than 30-minute interval data, it could eliminate the use of LMR Type II resources by DTE. The Company’s residential DR portfolio, which includes programs such as device cycling for air-conditioning and thermostat programs, have the capability to respond with very little notice, allowing for LMR Type II participation. However, as previously stated, the Company’s residential programs and metering infrastructure can allow for 30-minute reads, though not optimal. Anything more granular than 30-minute reads, such as 5-minute reads as proposed, is not available and would eliminate the Company from registering its residential resources as LMR Type II. Requiring this level of granularity would unnecessarily remove a fast-response resource simply because of an unneeded metering requirement. Additionally, it is not clear why MISO needs 5-minute meter reads. Since LMRs are given dispatch instructions on the top and bottom of the hours, 30-minute interval meter reads would be granular enough to capture if and LMR type II resource is able to deploy in time to meet its notification time requirement.

Voltus comments to RASC on RASC: LMR Accreditation Draft Tariff (RASC-2019-9)

December 9th, 2024

On November 6^th, MISO shared proposed Tariff language with the Resource Adequacy Subcommittee related to their proposals for capacity accreditation and participation for LMRs and demand resources in MISO’s footprint. Voltus appreciates the opportunity to comment on these proposed changes. 

Voltus offers the following feedback in response to MISO’s most recently shared proposals:

General Feedback:

MISO’s proposed language on a number of occasions references language in the Business Practices Manuals, particularly the BPMs related to Demand Response and Resource Adequacy, that is not yet present. Until such BPM updates are made, it is difficult to know if the language in the relevant Tariff sections accomplishes MISO’s goals. After continued discussion with stakeholders regarding substantive proposals, MISO should incorporate these proposals into proposed redlines to the BPMs and share these alongside proposed Tariff language in order to give stakeholders an appropriate body of information to provide comment on.

Module E-1

1. 35.0.0 – “The Market Participant shall, at all times, notify the Transmission Provider and Local Balancing Authority when the status or availability of an LMR changes”

   1. What is MISO’s proposed mechanism for notification between Market Participants and the Local Balancing Authority (LBA)? To increase efficiency and avoid human error, can LBAs be given access to submitted asset Availability (DSRI/MUI) to avoid a need for them and MPs to coordinate regarding availability?

2. 69A.3.1 – MISO’s addition of a mechanism for the replacement of Demand Resources that cannot meet their obligations is a welcome addition to Module E-1.

3. 69A.3.5 – MISO references a “Tolerance Band” related to an asset’s load as compared to its Firm Service Level: “The Transmission Provider will apply a Tolerance Band equal to ten percent (10%) when determining if a resource has deployed to or below its Firm Service Level.”

   1. MISO’s proposals otherwise do not give any significance to an asset deploying to its Firm Service Level, and this is confusing with the Tolerance Band in Schedule 53B related to Excessive/Deficient Energy and Capacity Availability. 

   2. This made is further unclear with MISO’s proposal in Section 69A.3.4 to remove language stating that an LMR may be deployed to achieve its targeted Firm Service Level. 

   3. MISO should clarify what deploying to within this 10% tolerance of an FSL means for an asset, and ideally redefine this with another name or, at least, the lowercase name “tolerance band”.

4. 69A.3.9 – MISO should add the following clarifying language: “the Market Participant responsible for that DRR or LMR shall make the same penalty payment as indicated in Section 69A.3.9.b, and that resource will not be eligible for Planning Resource status for the next three (3) Planning Years.”

Attachment TT

1. 3.i.a.f - “Unless an alternate approach is agreed upon by the Transmission Provider and a Market Participant representing an LMR and such alternate approach is documented pursuant to this Attachment TT, Measurement and Verification will be based on actual Load that is Metered in the Hour immediately preceding the issuance of the Scheduling Instruction.”

   1. As Voltus shared in our 12-04 comments related to MISO’s substantive proposals, this M&V ‘methodology’ is unclear, unduly punitive/rewarding to resources with volatile load, and MISO should instead create a baseline for hourly load using a similar methodology as for Seasonal Capability.

2. 4. MISO notes that “A Market Participant representing a DRR or LMR shall report to the Transmission Provider hourly meter data for all event and non-event hours for a given month” 

   1. For ARCs that have acquired appropriate authorization to access underlying customer usage data for their assets, MISO needs to  take steps to ensure that the relevant metering LBA/LSE provide ARCs with access to this meter data so that these submissions can be made by the required deadlines - otherwise, ARCs may be in violation of this despite taking all necessary steps to acquire the required data.

Schedule 53B

1. II “The Transmission Provider will provide a mapping of each Schedule 53B Resource to one of the Resource Classes set forth in Schedule 53A based on the registration of the Schedule 53B Resource” 

   1. MISO’s proposal is unclear for Demand Resources. What is the value of mapping Schedule 53B Demand Resources to a class in Schedule 53A? No class averages are used, and no such Schedule 53A class is similar to an interruptible Demand Resource

2. III.A MISO’s proposal states “Tier 2 Hours and Capacity At Risk Hours will not be weighted to calculate Emergency Seasonal Accredited Capacity for AME Resources, DRRs, and LMRs”

   1. As noted in our 12-04 comments, MISO should avoid weighting all Capacity At Risk hours the same - a capacity accreditation methodology that most appropriately determines assets’ value considers those hours with the tightest system operating margins as having a higher bearing on accreditation.

3. III.B.3.a 

   1. As additionally noted in our 12-04 comments, relying on a 24/7/365 Load Factor in instances where there is a Seasonal Emergency Hour Deficiency will inaccurately represent the Capability of resources, particularly HVAC resources. 

   2. MISO should redefine Load Factor to be the asset’s load factor in the N hours with the tightest system margins during the relevant Season, where N is the number of hours in the relevant Seasonal Emergency Hour Deficiency

4. III.B.3.a MISO defines the accreditation as being determined via their proposed calculation in “the most recent period beginning September 1st and ending August 31st.”

   1. Given that resource makeup will likely change each Planning Year, an asset’s composition between September 1st and May 31st could be completely different from its composition between June 1st and August 31st. MISO should align this calculation with the Planning Year.

5. III.B.3.c - MISO’s proposal for increasing Capability related to an increased Capacity Rating for Demand Resources appears reasonable, but Voltus requests further clarity and examples of how this mechanism would function.

6. IV.C “New Demand Resources or DRR or existing Demand Resources that do not have at least 60 days of real-time offered availability… will have a SAC based on its registered Load Factor multiplied by the Capacity Rating.”

   1. As noted above related to section III.B.3.a, pure Load Factor is an inaccurate way to accredit Demand Resources and will lead to both over- and under-counting accreditation for different asset types. MISO’s proposal will not lead to accurate accreditation of new resources and unfairly penalizes new Demand Resources that have a low 24/7/365 load factor but may otherwise be wholly available during hours of tight margins. 

   2. Instead, MISO should accredit new resources based on the average (Load minus FSL) during Capacity At Risk and Tier 2 RA hours, capped at its registered maximum Capability.

   3. MISO should also define an exception process by which MISO may adjust the SAC received by a given resource provided the enrolling MP provides sufficient justification for adjustments to SAC, such as growing load, a new load with insufficient historical data, or a meaningful change in operations that would increase availability or curtailable load.

Module A

1. MISO’s definition of “Shut-Down Time” should incorporate the following bolded language adjustments:  “...time required for a Demand Resource to reduce consumption equal to its Targeted Load Demand Reduction Level or to its Firm Service Level.

Respectfully submitted,

Sean Shafer

Energy Markets Manager

Voltus, Inc

The Entergy Operating Companies ("EOCs”)[1] appreciate the opportunity to provide feedback on MISO’s LMR Accreditation Draft Tariff. 

Demand Resource Eligibility 

In MISO Tariff redlines in section 69A.3.5 states:

 “Unless the Demand Resource is unavailable for reason of Force Majeure, when a Demand reduction is requested by the Transmission Provider for an Emergency, the resultant reduction must be a reduction within the Tolerance Band of the submitted Capacity Availability.  There shall be no penalties assessed to a Market Participant representing the entity that has offered ZRCs from the DRR or LMR if the Demand Resource is unavailable for reason of Force Majeure.”

These redlines remove other previously acceptable reasons for unavailability, including “local reliability concerns in accordance with instructions from the Local Balancing Authority”. The EOCs’ believe that if the Local Balancing Authority (LBA) activates a Demand Response resource, rendering it unavailable for MISO to dispatch, the resource should not be subject to penalties.

This same issue arises in the edits related to Behind-The-Meter Generation (BTMG) and in Section 69A.3.3. Additionally, the EOCs assert that planned maintenance is a legitimate reason why penalties should not apply to unavailable BTMG resources.

Penalty Provisions for DRRs and LMRs 

In the proposed redline for Section 69A.3.9 states:

“For any situation where the meter data submitted to Transmission Provider indicates that a DRR or LMR has increased Load during Hours covered by Schedule 53B, the Transmission Provider may initiate an investigation into the cause of such increased Load.  The Market Participant will be provided the opportunity to demonstrate such Load increase was justified based on reasonable business practices.  If the Market participant fails to provide adequate justification for such Load increase, the Transmission Provider may replace the hourly load factors as set forth in the Business Practices Manual for Resource Adequacy.”

The EOCs are requesting clarity on the general purpose and intent of the above edits and requests that MISO provide additional information regarding  “the transmission provider may replace the hourly load factors as set forth in the BPM for RA”.

 Attachment “TT” Redlines

Regarding the LMR Reforms Draft Attachment “TT” – specifically the section on “Events” – it is stated in subsection (4 – events) under meter data requirements:

“A Market Participant representing a DRR or LMR shall report to the Transmission Provider hourly meter data for all event and non-event hours for a given month by the last day of the month, two months afterwards (i.e., meter data for the month of January shall be reported by the last day of March). Meter data for hours not reported for a given month by the last day of the month, two months afterwards, shall receive a value of zero.”

However, in the “Event Timeline” section, the redlines state:

The time limits for a Market Participant that registers/enrolls the DRR or LMR to submit meter data for load curtailment activities are as follows:

a. Dispatched Energy: Up to 103 calendar days from the event date. An alert will be generated after 93 calendar days.

b. Ancillary Services: Up to five (5) calendar days from the event date.

The EOCs are questioning why this information is included in this specific section of Attachment “TT.” It appears to conflict with or override the requirement for reporting hourly meter data for both event and non-event hours within two months after the end of the month. Specifically, MISO’s stated requirement that “a Market Participant representing the DRR or LMR shall report hourly meter data for all events and non-events for a given month” seems inconsistent with the 103-day deadline for Dispatched Energy data submission.

This creates somewhat confusing language regarding the timing and process for meter data submission. Clarification is needed to ensure consistent and unambiguous requirements.

WPPI submitted an initial round of feedback for this item, which was posted on December 2.  Below we add a few comments on the posted tariff materials.

24. In the Attachment TT red-line posting, “hourly Metered energy” appears at section 2.  It appears that, for consistency with use elsewhere, both “hourly” and “energy” should be capitalized to refer to Module A definitions.
25. 69A.3.9.e of Module E-1 describes that MISO may be concerned “For any situation where the meter data submitted to Transmission Provider indicates that a DRR or LMR has increased Load during Hours covered by Schedule 53B.”  We presume that MISO’s concern would be gaming intended to inflate capacity value, but note that capacity value is based primarily on offered availability and not actual metered demand, and thus a DR would have no incentive to artificially inflate demand without reflecting this in reported availability.  Accordingly, it appears to us that the criteria above should be augmented to include the condition that reported availability, as well as actual demand, increase during the hours in question.
26. 69A.3.9.e of Module E-1 goes on to describe how MISO may adjust “hourly load factors” where it identifies an issue.  We note that this term is not defined.  We presume that what MISO would want to adjust would be the offered capability during those hours, and we would ask MISO to consider clarifying accordingly.
27. Schedule 53B.III.B.2(a.) describes how, when a DR engages in self-scheduling, “the amount of Load that is Self Scheduled” will be used in determining Capability for that hour.  How MISO plans to determine “the amount of Load that is Self Scheduled” is not described.  We would ask MISO to describe this calculation.
28. Schedule 53B.III.B.2(a.) iii describes the case in which “a Direct DR that has Self Scheduled and is not Available to reduce additional Load to or below the Firm Service Level in response to Scheduling Instructions.”  MISO should clarify that self-scheduling can legitimately reduce demand below the Firm Service Level and that this reduction will count towards Capability in the applicable hours.  To do otherwise, would be to fail to properly incentivize demand reduction when needed.
29. Schedule 53B.III.B.2(c.) describes the determination of Seasonal Capability in a manner that appears inconsistent with the Demand Resource Accreditation Example posted with the November RASC materials.  We would ask MISO to clarify which source provides the correct calculation.