LOLEWG: Resource Inclusion Criteria for the 2026/2027 PY LOLE Study (20240719)

WEC Energy Group recommends that all resources registered with MISO that are not in suspension, retirement or Catastrophic Generator Outage during a season should be included in the LOLE model for that season.

WEC Energy Group also supports the inclusion of replacement capacity within the LOLE model for any modeled planned outages that exceed 31 days.

DTE appreciates the opportunity to provide feedback on the set of criteria used to determine which resources should be included in the LOLE model. Since the LOLE model determines both the PRM and the class-level accreditation under DLOL, DTE believes resources should be included in the model for each season that they are likely to be available for during actual operation. Following this logic, any resource that FRAP and/or offer in a season should be included in the LOLE model for the corresponding season. 

Additionally, units excluded from a season should be considered for inclusion in the LOLE model depending on the circumstance of their exclusion. If a resource is excluded due to outage duration greater than 31 days, it should still be included in the LOLE model unless it has been excluded from the same season in two consecutive PRAs. In DTE’s experience, a resource may be excluded in one season for a long duration outage, but the same resource will not have an extended outage during the same time the following year. Since the unit will be able to operate in the same season the following year, it should be included in the LOLE model. However, if a resource is excluded from the same season in two consecutive PRAs due an outage lasting longer than 31 days, this indicates that the resource consistently has long duration outages during a specific season and should not be modeled in the LOLE for that season. If a resource is excluded due to suspension, this indicates that resource will not be available for future seasons, and in this instance, it should not be included in the LOLE model. Applying the same logic to external resources, DTE believes that those resources should not be included in the LOLE model if they do not clear in the PRA, as it is possible that they will sell into a different market the following year to gain revenues and MISO cannot rely on them.   

In addition to the comments above, DTE would like MISO to expand on the rationale of comparing offers to the seasonal auction clearing prices to determine which resources to include in the LOLE model. What are the perceived benefits of selecting resources with this method?  

The Entergy Operating Companies ("EOCs")^[1] appreciate the opportunity to provide feedback on MISO’s resource inclusion criteria.

The EOCs believe that the following criteria should be implemented by MISO for determining which resources to in include in the annual LOLE study.

• Remove suspended/retired units from LOLE study
• Resources that FRAP or Offer in prior PRA should be included in the current LOLE study (regardless of if the unit cleared in the PRA)
• Resources that receive an IMM exclusion in prior PRA because of a long duration planned outage should be included in the current LOLE study
• Resources that received an IMM exclusion in the prior PRA for any reason other than a long duration planned outage should not be included in the current LOLE study

The EOCs believe that there needs to be further discussion about inclusion of wind/solar resources based on ERIS vs NRIS considerations. If all wind/solar resources with only ERIS are being included in the LOLE model, then we are likely overestimating the amount of wind/solar that will actually participate in the PRA because all of these ERIS units do not obtain NITS or Firm Transmission Service to qualify as a capacity resource.

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

Clean Grid Alliance appreciates this opportunity to submit feedback to MISO.

MISO should extend the initial resource set currently used for the LOLE Study to include all generators included in the LSEs’ annually submitted forward supply plans plus any generators reasonably expected to be capable of providing Energy with any required transmission or distribution interconnection service in the subject upcoming Planning Year.  That is a reasonable approach for several important reasons, including because it would:

• Help the LOLE Study resource set mimic the set of resources from which the IMM expects economic PRA offers (unless the allowed offer price clearly would exceed whatever multiple of $Annual CONE/MWd is used to define excess revenues post-RBDC implementation);
• Help make the LOLE Study more internally consistent in terms of (effective) inclusion of all renewables with interconnection service in the LOLE Study;
• Help the LOLE Study model capture the existence of spare capacity held for replacement purposes (even though the LOLE Study accounts for expected planned outages); 
• Help avoid some sort of vicious cycle – or worse – that will increasingly harm load exposed to Planning Resource Auction (PRA) clearing prices, which could be created by accreditation reform and forecasted demand growth.  Such unwanted outcomes could happen if capacity requirements keep rising as capacity auction shortages keep getting worse, which is the sort of situation that PJM Base Residual Auction observers are already using to warn about an “ELCC death spiral.”  (For MISO purposes, it might be called the “DLOL death spiral” if FERC approves MISO’s accreditation proposal); and
• Help MISO maintain consistency with MISO and OMS messaging after the 2022-23 PRMR shortage – i.e., that the PRA shortage did not pose a reliability risk because there was more eligible and available energy supply than just the accredited capacity cleared in the PRA.  Besides, this recommendation conservatively ignores non-External NRIS external supply and demand-side resources not already captured in LSE supply plans (which is appropriate since their PRA participation is more purely voluntary). 

I am happy to discuss. 

David Sapper (dsapper@cleangridalliance.org)

Minnesota Power appreciates the opportunity to submit stakeholder feedback.  Thanks for providing this guidance on submitting stakeholder feedback.

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Historically, converted capacity from the most recent PRA is used as a starting point for resources to be included in the LOLE model.  MISO requests that stakeholders offer proposals on a set of criteria that determines resource inclusions in the LOLE model. Some considerations that have been discussed are: 

• Resources that FRAP and/or offer in a season may be available for only the corresponding season
• Resources that FRAP and/or clear in a season may be available for only the corresponding season
• Resources that FRAP and/or clear in one season may be available for the entire study period
• Should a granted IMM exclusion in the PRA be assumed to happen again in future corresponding seasons?
• Should offers be compared to the seasonal Auction Clearing Price and/or an average over the last several years?
• Should there be different considerations for varying resource types, i.e., external resources?

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Minnesota Power believes that the LOLE model should include all offered capacity for any season it is offered.  The impact of an IMM exclusion should not included in the LOLE model in any season.  The pricing in a PRA should not be considered as a criteria for available capacity in the LOLE model.  PRA pricing should not impact the basic criteria of the LOLE model having all available resources.  

Thanks again for providing the opportunity for stakeholder feedback.