RASC: Regional Resource Assessment (RRA) Feedback (20231107-08)

How does MISO improve Zone 4 Capacity by 2027?

How & Where will capacity develop in Zone 4?

How much capacity will retire in Zone 4 over the next 10 years?

The page 7 slide shows the projected short positions in Zone 4,  little for Zone 5,  & the excess supply in Zone 1 - 3 is going away by 2027.

Bob Kosner

IMEA

Alliant Energy finds the following information useful for resource planning purposes and conceptualizing the RRA process and results:

• Summary of LSE long-term plans and MISO’s added resource to supplement those plans for reliability needs.
• Short / medium / long-term footprint and zonal capacity positions
• Seasonal accreditation rates over time by resource type

 We recommend that MISO consider reliability attributes impacts in future RRA work.

In the MISO JuiceBox, please consider adding SAC values to unit descriptions, instead of just ICAP values.

DTE appreciates the opportunity to provide feedback on MISO’s RRA. The most valuable data from the RRA will be the forecasted seasonal out-year DLOL results, categorized by resource class. DTE supports MISO’s idea to include a provision in the DLOL tariff update, stating that MISO will supply out-year DLOL forecasts. These projections will assist stakeholders in examining a broad spectrum of capacity scenarios, an important step for various activities, including the development of integrated resource plans. DTE would also support unit-level data in Juicebox being made available to download by market participants throughout the year, instead of only when the Juicebox data entry period is open. Having this data will allow market participants to have a better understanding of MISO’s capacity position as a whole. Currently, DTE does not have requests for additional analysis or suggested improvements to the emissions dashboard.  

The NDPSC recommends that MISO study the effect of dispatchable retirements on the RRA portfolio. MISO should perform a chronological assessment of renewable energy showing how the system is served reliably as dispatchable resources retire over time. The assessment should show how load is served net of renewable dispatch using an hourly dispatch, how the system operates and maintains reliability during hours when renewable generation exceeds and falls short of load, and how the retirement of dispatchable generators affects this view over time. MISO should consider the addition of age-based retirement assumptions around the gas fleet to further inform the assessment. This may help to inform stakeholders on how best to integrate renewable generation alongside retiring dispatchable generation and on the type of investments which may be needed to support their goals. We urge MISO to then hold a workshop on the results.

Clean Grid Alliance Feedback on MISO’s Regional Resource Assessment

December 30, 2023

Clean Grid Alliance appreciates the opportunity to provide feedback on MISO’s Regional Resource Assessment.

Reporting of more granular emissions rate data would be extremely helpful to end-use stakeholders who comply with GHG accounting and electricity decarbonization goals and/or strategies.  Specifically, a granular (e.g. nodal, zonal, regional, and BA-level data) of average and marginal CO2 emissions rates on a 15 minute basis.  If MISO could begin forecasting these rates (similar to California’s Self Generation Incentive Program https://content.sgipsignal.comon)  a day ahead basis, those forecasts could be used by market participants to schedule contracted energy storage facilities around carbon and not just LMP as they are today. The need for this data was featured in MISO’s 2021 Forward report available at https://cdn.misoenergy.org/MISO%20FORWARD%202021545008.pdf. MISO publishes the marginal fuel type by region, which does not provide sufficient information to support end user “use” cases. Below is some additional information on the need and benefits of providing such information: 

1. The 2021 Infrastructure bill included language directing EIA to publish both marginal and average emission factors on an hourly basis across each BA. Although the bill states the need for “real-time” data, for reporting purposes real-time is not necessary, and a data lag may be more appropriate to allow time for market corrections for settlement quality data to be used. “Resources for the Future” ran a stakeholder process and issued a report of options the EIA could pursue to fulfill the congressional directive.  This report (available at https://www.rff.org/publications/reports/options-for-eia-to-publish-co2-emissions-rates-for-electricity/) and is a good primer on the issue, the use cases, and methodology approaches RTOs and the EIA could pursue. Given the varied approaches, Clean Grid Alliance encourages full transparency in the methods that are used to calculate the marginal rate.

2. CEBA (Clean Energy Buyers Association) has summarized the federal opportunity in a blog, which can be found at https://cebuyers.org/blog/energy-customers-want-transparent-precise-reliable-emissions-data/

3. Several large data center customers worked to compile a 2 page RTO data “wish list” for emission factor data and high level methodology options.  This document is included with these comments as an attachment.  Since the compilation of this document, there has been a collaborative industry effort to develop an ISO standard API, called the Carbon Data Specification for Power Systems Data. We encourage MISO to provide feedback to this standard and leverage it when considering how and what data to make available: https://powersystemsdata.carbondataspec.org/specs/cdsc-wg2-03/.

We appreciate MISO’s consideration of this feedback and look forward to future discussions on the benefits and possibilities of providing more granular data.

The Environmental Sector appreciates the opportunity to provide feedback on MISO’s 2023 Regional Resource Assessment. Our feedback follows the three specific items requested by MISO in turn. At the outset, we recognize that some of our feedback may be addressed as a matter of course when MISO returns to a fuller scope in 2024. 

Insight into what RRA information is most useful and use cases

1. The most useful information shared in the RRA is the future projected resource mix on an ICAP and UCAP basis and the projected accreditation values over time for each resource class. We are looking forward to the next iteration of the RRA Report, when it covers a fuller scope that includes updated member plans, state and utility goals, other policy and economic signals, and updated resource adequacy information.
   
   

Requests for additional analysis and ideas for future iterations

1. Additional information and/or detail are always welcome. While Juicebox does provide some of this detail, it is forward looking only, and the visual displays provide only rough data (e.g. “< 5MW”). Although .csv files may be downloaded from the Juicebox to get more exact data, we believe it would be even more helpful if MISO also made this data easily accessible in a non-Juicebox format, e.g. via standalone charts or spreadsheets. Juicebox would also be enhanced if it included prior-year information. 
2. Similarly, many of the charts and graphs in the report lack full numerical details that may be helpful to stakeholders. Prior-year information is also usually lacking, and we believe that incorporation of prior-year data on these same charts or spreadsheets (or in Juicebox) may be helpful. Examples of such annual data could include:
• Fleet MW values, including prior year change (additions and retirements)
• Accreditation values for each resource class in MW
3. Part of the RRA effort should also look to what RRA projections were in the past to compare them with current RRA projections. This would give interested parties an easier way in which to see the change in expectations over time, which would aid in understanding current projections better. As an example, in MISO’s work with the Futures, it did a good job comparing the expectations of Series 1 with Series 1A, enabling all parties to see how quickly the business, policy, and operational environment is changing (faster than we thought). 
4. Slide 30 of the RRA Report indicates that it used Future 2A expansion modeling, yet slides 31 and 32 reference Future 1 with respect to load growth. Is this a typographical error, or did the RRA indeed utilize Future 1 load growth projections? If the latter, future iterations should look to a more aggressive load growth scenario than that supplied by Future 1. If this was a necessity because the 2023 RRA is only a “refresh” of the 2022 results, or because of some other reason, that information should be explicitly stated. 
5. Since the 2023 RRA is published as a slide deck, we think a useful amendment would be the inclusion of an Expected Fleet Chart for the full MISO footprint somewhere between slide 20 and slide 22, just as the same chart is provided in the Appendix for each of the LRZs, e.g. on slide 42 for LRZ 1. 
6. Although the RRA is predominately forward looking, it should also provide data for generation that has entered commercial operations in recent years to provide insight on the yearly pace of new generation additions in the MISO fleet.
   
   

Suggestions for improvements to the Emissions Dashboard, including requests for additional emissions data and use cases

1. Overall, the Environmental Sector likes the Emissions Dashboard and sees it as a useful tool in MISO’s internal processes, external stakeholder meetings, and elsewhere. While we understand some of its limitations (e.g. confidential planned units are listed as “model built”), this tool is one we hope will better inform future discourse as MISO makes iterative improvements to it going forward.  
2. We are glad to see storage listed as an “expanded fuel type,” but considering its importance we believe it should be listed under the fuel type drop down without needing to make such selection visible in the settings. The tutorial that begins upon opening the Dashboard should also include information about expanding “Other” within the settings.
3. With respect to storage, we note that the Dashboard currently shows storage as having no contribution towards additional emissions. However, to the extent that storage charges from carbon-emitting resources, its round-trip efficiency losses may result in some additional increase in emissions. We recognize that this particular nuance may not yet be appropriate for inclusion in the Dashboard itself, but we encourage MISO to start considering how storage is impacting emissions, including its locational aspects, and also include a new section in its RRA Report regarding this issue.
4. We noticed that at least one planned long duration storage unit in MN is not included in the Emissions Dashboard. MISO should ensure that this unit and other long duration energy storage units are added to the Dashboard. Likewise, it would be beneficial to separate electronic storage into short-term and long-term duration.
5. We also noticed that other generating resources were geographically misplaced within the Dashboard. For example, we didn’t see the F.B. Culley units in southern Indiana, and the D.B. Wilson unit is shown as being in Indiana, but it's pretty deeply into KY. We understand that the Dashboard is still young, so we hope that similar such discrepancies will be fixed soon.
6. We did not see a way in which to download unit-specific data in the Dashboard (e.g. all energy wind units in LRZ 1). It would be useful to have such capability or otherwise make such capability more readily accessible within the Dashboard. 
7. As great as the Emissions Dashboard is, its usefulness could be more fully leveraged if stakeholders had access to–or at least knowledge of–the underlying methodologies used to create its forward-looking estimates. We suggest that MISO make this information available, or more easily so to the extent such information is available but not coupled with the RRA Report. 
8. There are a few bugs here and there, such as the existence of a geothermal unit in LRZ 1 that is not visible on the map, but which shows up in the electricity generation chart (this may be due to the icon for geothermal plants being the same color as the LRZ 1 shaded area). 
9. Later iterations of the Emissions Dashboard could be enhanced by including greater temporal and spatial granularity. As an example, a heat map could show how emissions change across the region and within each LRZ over time (e.g. by month or season). 
10. Finally, we reiterate that we are very encouraged by MISO’s publication of the Emissions Dashboard. Any of our comments with respect to the Dashboard should not be taken to disparage or otherwise discount MISO’s efforts in creating it.