In the April 18, 2024, meeting of the Market Subcommittee (MSC) stakeholders were invited to review and submit feedback on Demand Response Participating as a Supply Resource in MISO Markets.
Please provide feedback on the following:
Please provide feedback by May 2, 2024.
American Municipal Power (AMP) appreciates the opportunity to provide feedback on Demand Response Participating as a Supply Resource in MISO Markets and offers the following comments:
AMP is supportive of continued stakeholder discussions on proposed solutions to address the problems identified with Demand Response. AMP encourages MISO to connect the disparate initiatives regarding demand response participation that have been discussed in recent RASC and MSC meetings in an effort to improve overall market design. In all of these separate initiatives, MISO pointed out flaws and concerns regarding the current market design. These initiatives need to be combined and a long-term vision for demand response needs to be developed. A better understanding of the end goal would help in the design and timing of all the demand response reforms being discussed at MISO.
WPPI offers the following feedback on the demand response participation rules presentation at the 4/18/2024 MSC:
Comments
of the
Association of Businesses Advocating Tariff Equity (ABATE),
Illinois Industrial Energy Consumers (IIEC),
Louisiana Energy Users Group (LEUG),
Texas Industrial Energy Consumers (TIEC),
Coalition of MISO Transmission Customers (CMTC),
Midwest Industrial Customers (MIC)
and
Midwest Large Energy Consumers (MLEC) [1]
Regarding
MSC: Demand Response Participating as a Supply Resource in MISO Markets (20240418)
May 2, 2024
ABATE, IIEC, LEUG, TIEC, CMTC and MIC and MLEC appreciate this opportunity to provide comments to MISO.
In response to concerns with the past Demand Response Resource (DRR) participation of certain entities and the alleged activities of Ketchup Caddy with respect to registering retail electric customer load as Load Modifying Resource (LMR) without the consent of the associated retail electric customers,[2] MISO at the April 18, 2024 MISO Market Subcommittee (MSC) meeting proposed to make a number of changes to address the following issues:
In addition, MISO is proposing two other changes for DRRs that are not tied to the aforementioned concerns:
In general, we support reasonable reforms to address concerns with payment to DRRs for artificial curtailments and inflated DRR baselines. However, at this time, MISO has not provided enough detail with respect to its specific proposals to address these concerns for us to address the reasonableness of those proposals. We look forward to MISO providing additional detail on these specific proposals.
With respect to MISO’s proposal to address fraudulent registration of retail electric customers as DRRs, LMRs or EDR, we conceptually support MISO’s proposal to require Aggregators of Retail Customers (ARCs) to submit signature pages of the contracts ARCs have with retail electric customers to help assure those ARCs have received consent from those customers to be registered with MISO as demand response. However, with respect to MISO’s proposal to also impose the requirement on all other Market Participants as well, we would caution that in some cases the Market Participant is the retail electric customer or is a wholly owned subsidiary of the retail electric customer whose sole purpose is to be the market participant for the retail electric customer (e.g., in Illinois when the retail electric customer, or its wholly owned subsidiary, is certified by the Illinois Commerce Commission as a Subpart E Alternative Retail Electric Supplier). In such situations, the Market Participant and the retail electric customer are one in the same, or essentially one in the same in the case of a wholly owned subsidiary. As a result, there would be no contract between the Market Participant and the retail electric customer. MISO should not require demonstration of a contract in this situation.
With respect to MISO’s proposed modification of the current Reference Level calculations, economic withholding thresholds and uneconomic production thresholds of Module D of the MISO Tariff with respect to DRRs, MISO has not defined the problem it would be trying to address through such changes. In addition, MISO has not identified the specific changes it would propose. We do not support any changes to these provisions without MISO clearly explaining the problem it would be attempting to address with such changes. We would also caution that no retail electric customer is required to provide demand response. Hence, retail electric customers have an implicit right to physically withhold participation. As a result, the concept of economic withholding for demand response makes little sense because retail electric customers have the implicit right to physically withhold participation by choosing not to participate in providing demand response. We recognize MISO’s concerns may be related to market participants who both aggregate demand response and participate with other resources in the MISO market such as with generation resources. However, if that is the case, MISO’s proposal should be narrowly tailored to such situations. Regardless, no proposal should be put forth by MISO until it has clearly identified the problem it is trying to solve.
With respect to MISO’s proposal to subject DRRs to an energy offer price floor equal to the MISO Order No. 745 NBPT value which MISO indicates ranged from $28 to $52 per MWh over the past year, MISO has once again not defined the problem it would be trying to address through such a change. We do not support the proposed change without a clear explanation as to the problem MISO would be attempting to address with the proposed change. Furthermore, we do not understand MISO’s claim that such an offer floor would be consistent with Order No. 745. Order No. 745 does not establish or require such an offer price floor. The sole purpose of the Order No. 745 NBPT is to determine when demand response participating in the energy market is eligible to receive a full Locational Marginal Price (LMP) payment rather than one which is reduced.
Thank you for providing us an opportunity to provide the above comments. If it would be of help, we would be glad to discuss the above comments further with MISO and other stakeholders. If you have any questions regarding these comments, please do not hesitate to contact any of the following representatives:
Jim Dauphinais
Brubaker & Associates, Inc.
(Consultants to ABATE, IIEC, LEUG and TIEC)
(636) 898-6725
Ali Al-Jabir
Brubaker & Associates, Inc.
(Consultants to ABATE, IIEC, LEUG and TIEC)
(361) 994-1767
Ken Stark
McNees Wallace & Nurick LLC (for CMTC)
(717) 237-5378
Kavita Maini
KM Energy Consulting, LLC (Consultants to MIC and MLEC)
(262) 646-3981
[1] ABATE, IIEC, LEUG, TIEC, CMTC, MLEC and MIC are all MISO Members in the End-Use Customer Sector.
[2] See “Order to Show Cause and Notice of Proposed Penalty,” Ketchup Caddy, LLC and Philip Mango, Docket No. IN23-14-000 (Issued Feb. 21, 2024).
DTE Feedback
DTE appreciates the opportunity to submit feedback on Demand Response (DR) participating as a supply resource in MISO markets, and understands MISO’s concern with payments for artificial curtailments, inflated baselines, and fraudulent registration.
Overall, DTE believes that while “administrative controls” (requirement of signatures, executive attestations) may help mitigate instances of incorrect behavior, requirement of robust data submission and validation processes are necessary to ensure resources are being appropriately compensated for the services they are ultimately providing to the market.
Artificial Curtailments
DTE agrees with MISO that it is prudent to require regularly updated meter data for all DRR Type I/II and LMRs, including non-event hours. We strongly believe MISO should implement processes that ensure accuracy and validity of the submitted meter data. While requiring executive attestation following deployment could help to reduce incorrect behavior, it will not eliminate said behavior, all while adding complexity to the process. MISO needs to assume an active role in performing accuracy review of the data submitted by aggregators, supplemented by Electric Distribution Companies (“EDCs”) (as described below).
DTE Electric would like to emphasize the importance of consistent enforcement of Tariff requirements across all market participants, including aggregators. Specifically, we recommend that MISO holds DR aggregators accountable to the meter data quality provisions outlined in the MISO Tariff. The relevant sections are as follows:
MISO should request evidence of compliance for metering equipment used by DR aggregators when enrolling DR resources to MISO. By ensuring that aggregators comply with these Tariff provisions, MISO could help to mitigate fraudulent data submissions, data manipulations (safeguarding against unauthorized alterations of meter data), and illegal subsidies.
Load Serving Entities (LSEs) and Load Balancing Authorities (LBAs) play a crucial role in the process of ensuring meter data accuracy within the MISO framework, provided they have access to the necessary tools and processes. Currently, MISO’s process restricts LSEs and LBAs from viewing meter data submitted for their service territories until S7, S14, S55, and S105 statements are published. Given that the initial meter data collection, validation, and submission process can take over 14 days, this leaves LSEs and LBAs with only two attempts to validate meter data submissions and address any issues. Specifically, if a Market Participant fails to correct meter data by S55, LSEs/LBAs have just one chance to address the issue using market tools. This approach limits the ability to establish effective processes for ensuring meter data accuracy. To address this, we recommend that MISO should publish a daily Residual Load Adjustment (RLA) statement for all market days up to S105 (not just S7, S14, S55 and S105). This statement should include all submitted meter data to facilitate thorough validation. By implementing this change, we can strengthen accountability and promote accurate meter data across the MISO ecosystem.
Further, the automatic approval feature of meter data in MISO Demand Response Tool (DRT) inadvertently creates a lack of accountability for Load Serving Entities (LSEs) and Load Balancing Authorities (LBAs). Given the growing significance of distributed resources, including Demand Response, in serving MISO load, and with the impending compliance with FERC Order 2222 (which aims to remove barriers to participation in the wholesale market), it is crucial to establish robust rules that foster transparency and diligence among all market participants. Rather than delegating the meter data review and approval process solely to LSEs/LBAs, MISO should require Electric Distribution Companies (EDCs) performing LBA functions to submit meter data for the DR aggregations. MISO’s DRT can then automatically deny aggregator meter data if it falls outside a defined threshold not matching EDC-provided billing quality readings. This approach would help to ensure the accuracy of meter data provided by aggregators and mitigates the risk of fraudulent submissions.
Separately, DTE would also request clarification on what DART changes MISO is proposing (Slide 11). MISO/IMM has full authority to question offers they view as being incorrect or unattainable with ability to investigate and enforce the Tariff.
Inflated Baselines
DTE agrees that there are currently issues with MISO’s baseline methodology which allow for market participants to inflate their baselines and receive undue compensation for demand reduction that may not be real. To enhance the monitoring of expected baselines and reductions, DTE supports MISO’s proposal to define a potential process for DRR testing, though, given the MISO’s recent LMR reform proposal and the resulting potential for large industrial customers to participate as DRRs in the future, it is critical that the economic impact of testing is appropriately considered (please see further comments in DTE’s response to the MISO feedback response titled “RASC: Accreditation Reforms for LMRs [20240417]”). Additionally, DTE encourages MISO to consider expanding their current baseline calculation options to include additional variables and a more diverse set of methodologies. MISO’s current baseline calculation methods are narrow and may not allow market participants to correctly capture their true baselines. Stakeholders may also benefit from a more focused discussion on MISO’s baseline methodologies as in DTE’s experience it is not always evident which of the existing methodologies are the best suited for specific demand response scenarios.
MISO’s other proposal to screen offer parameters to mitigate inflated baselines is promising. However, further discussions are necessary to address key questions. These include determining which party will be responsible for screening offer parameters and establishing criteria for deeming an offer parameter acceptable. DTE agrees in principle that offer parameters should undergo screening, the specific process to do so must be discussed in greater detail. A possible solution to avoid inflated baselines is to have the EDC submit meter data on behalf of the aggregator - but that raises other complications.
Fraudulent Registration
DTE recognizes that implementing administrative measures, like mandating signature pages from ARCs and MPs, can mitigate improper conduct. However, to efficiently prevent fraudulent registrations, MISO should emphasize operational controls. This includes ensuring meter data feeds are accurate and testing procedures are followed. Furthermore, should any inconsistencies in operational data be identified, MISO should investigate to ensure resources are registered correctly.
Additional Proposed Tariff Requirements
DTE agrees that some degree of change should occur in Module D to allow the IMM oversight of DRR offers. However, this would be a substantial effort with many complexities. DTE encourages MISO to provide further details on how DRRs would be classified, the granularity of reference levels, and implementation plans. Given MISO’s proposed changes to LMR accreditation, it is reasonable to expect higher volumes of registered DRRs and MISO will have to determine how the reference level calculations will align with these changes. DTE is supportive of a DRR offer floor to be at least the NBPT, which we feel will prevent gaming in periods of low market.
TO: | MISO MARKET SUBCOMMITTEE |
FROM: | THE ENTERGY OPERATING COMPANIES |
SUBJECT: | DEMAND RESPONSE PARTICIPATING AS A SUPPLY RESOURCE IN MISO MARKETS |
DATE: | MAY 2, 2024 |
The Entergy Operating Companies ("EOCs")[1] appreciate the opportunity to provide feedback on MISO’s Demand Response Participating as a Supply Resource in MISO Markets. The EOCs comments regarding the feedback requested is provided below.
MISO has identified several instances of inappropriate market behavior concerning demand resources and is considering new tariff rules and BPM practices to address these issues. In addition to this MISO has raised concerns that Demand Response Resources (DRRs) are receiving payments from the MISO market for purported reductions in load that did not occur.
The EOCs inquire about the frequency with which calculated or custom baselines contribute to these issues and propose that Demand Response participation should not rely solely on calculated data. Instead, participants should provide meter information i.e. load/generation data, depending on the chosen consumption baseline method. Metering requirements for Demand Response registration should include:
The EOCs believe that submitting meter data would help resolve issues arising from inflated or manipulated resource performance and ensure the resource's ability to provide energy/capacity, thus reducing false payments/performance issues.
Concerns are raised regarding MISO's proposed solution of requiring executive attestation on DRR reductions, similar to the process in Schedule 30 for Energy Deficiency Restraint. This could impose significant administrative burdens on MDMA/MP due to the frequent occurrence of DRR market activity.
The EOCs seek clarification on system changes to DART intended to limit offers consistent with the resource's ability. Additional information on this matter is required.
Further discussion and clarification are requested regarding the process flows through the RERRA, including contact points and the approval process. Transparency in this process is deemed essential for all involved entities to access and review information submitted by all parties. Additionally, stronger rules/processes are suggested at the customer level regarding registration for various Demand Response programs.
Voltus comments to MSC on “Demand Response Participating as a Supply Resource in MISO Markets (20240418)”
Voltus appreciates the opportunity to comment on proposed changes to Demand Response Resources related to their participation as Supply Resources in MISO’s markets.
Payment for Artificial Curtailments
MISO’s proposal to require DRRs providing energy to provide meter data for all hours in order to provide MISO with the ability to better monitor market behavior is reasonable in principle. Implementation rules should be designed to avoid an unreasonable administrative burden, both for MISO and for participants. For example, if data submissions are required more often than monthly, there should be an API or other submission option to support automated submissions.
MISO’s proposal to require an executive attestation on DRR reductions is reasonable. With this said, MISO should institute a process to collect these attestations as efficiently as possible. Submitting attestations during registration of an asset similar to attestations provided for LMR and EDR enrollment is reasonable, whereas requiring new attestations for each load curtailment event would be extremely onerous to market participants.
Voltus views MISO’s proposal to make system changes to DART to limit offers consistent with the resource’s ability as unreasonable. While MISO should take appropriate steps to audit offers to ensure no market-gaming behavior is ongoing, there are many situations where limits to DART offers should be carefully designed to avoid penalizing rule-abiding resources. DRR-Type I assets in particular are often aggregations of multiple resources. One of the subset loads may experience downtime while the other remains operational. For example, one DRR may include a 1 MW and a 50 MW load. In such an instance, it would be unfair of MISO to institute offer limits that would prevent the aggregated asset from offering 1 MW while the larger load is removed from participation during its downtime, or from offering 51 MW once it returns. The abilities of a resource may also change over time, for example as a load grows or changes, automates curtailment, or simply gains experience with demand response. There should be some path for DRRs to submit offers that exceed their previously-demonstrated abilities as these abilities change.
Finally, while DRR-Type I assets are defined as all-or-nothing resources, each individual load comprising a given DRR-I may have a different price at which it is willing to respond. In other words, an aggregated DRR-1 may be able to provide different levels of curtailment at different prices. As such, MISO as a part of its updates to DRRs should allow for multiple P-Q pair offers for DRR-Is as Voltus previously requested in an Issue Submission submitted on 7/6/2023. This will give market participants more flexibility in their offers, increase the volume of demand response offering into the energy market, and provide a valuable record for MISO that can be used to contextualize offer behavior for any given asset.
Inflated Baselines
Voltus requests further clarification from MISO on the proposal to consider specifying how and when DRR testing must occur. In principle, such a proposal is reasonable. However, Voltus cautions MISO against instituting testing policies that are excessively onerous for MPs or for underlying loads, especially for DRRs that routinely demonstrate their abilities through market-based dispatches. MISO should focus on instituting testing policies only in situations where an audit of meter data or performance data raises questions.
MISO’s proposal to change calculated baselines to exclude event hours rather than event days for baseline calculation is reasonable. MISO should additionally preclude hours that are adjacent to event hours, as facilities curtailing for Demand Response purposes may curtail during the hour prior to event hours (if they have received an advance dispatch instruction and have time to start early) as well as ramp load after event hours. It is unreasonable to assume that DRRs will only curtail for the exact minutes during which they receive Scheduling Instructions from MISO - they will necessarily take some time on either side of an event to reduce and restore load.
Voltus requests clarification from MISO on the proposal regarding methodology of baseline calculation when MISO does not have sufficient non-event hours. For the avoidance of doubt, MISO should not consider any baseline methodology that includes in the baseline calculation period any load during event hours. Any such methodology would not appropriately determine a baseline for an asset that has been curtailing in response to MISO scheduling instructions.
Voltus requests additional clarification from MISO on the methodology that would be used to screen offer parameters to ensure they are consistent with resource’s abilities.
Fraudulent Registration
Voltus supports MISO’s proposal to require MPs to submit signature pages of contracts with end-use customers for registration of demand response assets. For the sake of efficiency, it would be beneficial for MISO to maintain a DER registry that associates DERs with MPs by time interval and the products each MP is authorized to provide while utilizing that DER. This would remove redundancies associated with registration of the same asset as an LMR, EDR resource, and DRR. MISO should monitor for duplicate enrollments by multiple market participants, and should allow market participants to defend their claim to duplicate enrollments by providing contracts.
Module D Enhancements
MISO has proposed to institute Reference Level calculations for DRRs. Voltus is supportive of MISO instituting policies that may identify bad actors, but cautions MISO that it is not reasonable to introduce a new, onerous process for all DRRs. If Reference Level calculations are to be required for DRRs, they should only be for situations where a DRR has placed offers well outside of its normal offer parameters or is offering at a price outside of market norms. MISO should avoid requiring significant detail and sensitive information to calculate Reference Levels for DRRs, in recognition of the fact that DRRs are composed of end user facilities with highly variable and proprietary cost calculations. Instead, MISO should default to basing Reference Levels on the mean or median of Energy offers in competitive periods over recent timeframes – similar to how generating assets’ Reference Levels are based on rolling 90 days mean or median offers.
Voltus requests clarification on MISO’s proposal to make adjustments to thresholds for economic withholding and uneconomic production. We are unable to comment on these proposed changes without additional information on what is being proposed.
DRR Offer Floor
Voltus supports MISO’s proposal to require offers for Energy in the DA + RT markets to be floored at the NBPT value. This is in line with FERC 745. However, at the time of instituting this change, MISO should make updates to its MUI that flag offers above the NBPT to the market participant submitting such offers.
Other Considerations
MISO should review the cap that limits DR to 40% of spinning reserve service clearing, as Voltus has requested in a previous Issue Submission dated 10/24/2023. We believe the ongoing review of DRR performance will demonstrate that DRRs provide adequate performance, and the cap is unfair to MPs offering reliable assets. PJM recently removed their own similar cap to allow for increased competition to reduce spinning reserves costs.
Other thoughts on prevention of market gaming
Voltus would support a random audit mechanism, including measures such as occasional direct contact of end use facilities, to confirm the curtailment abilities of demand response assets.
Respectfully Submitted,
Sean Shafer
Senior Energy Markets Analyst
Voltus, Inc
Wabash Valley Power Alliance (“WVPA”) appreciates the opportunity to comment on Demand Response Participating as a Supply Resource in MISO Markets. We support MISO’s effort to identify and prevent inappropriate market behavior and generally support MISO’s proposal to achieve that effort, but request that MISO maintain flexibility in the planned approach to accommodate the diversity of demand response resources.
Specifically, WPVA appeals to MISO to exclude small device-based demand response assets, such as aggregated air conditioners, pumps, water heaters, etc. from the proposed requirement for market participants to submit signature pages of contracts with end use customers. This approach will be more feasible for aggregations which may include thousands of devices. The underlying demand response programs are often based on utility retail tariff provisions or digital consents to terms and conditions agreed to by existing participants, rather than formal contracts.
CPower Comments to MISO Regarding Demand Response Participation Rules Presented on April 18, 2024 to the MSC
May 2, 2024
During the April 18, 2024 MSC meeting, MISO presented several issues and proposed solutions to address participation by Demand Resources in the MISO’s markets. Enerwise Global Technologies, LLC d/b/a CPower (“CPower”) appreciates the opportunity to provide feedback to MISO on these issues. CPower thanks MISO staff for their review and consideration of the feedback below. Should you have any questions, please do not hesitate to contact Peter Dotson-Westphalen.
MISO’s presentation highlighted three problems with Demand Response, including payment for artificial curtailments, payment for inflated baselines, and fraudulent registration, and requested stakeholder feedback on: 1) whether or not we agree with the proposals or have alternative solutions to offer to address instances of market manipulation, 2) whether there are other matters related to DR participating as a Supply Resource that need to be addressed, and 3) whether or not we are in favor of the proposed offer floor for Demand Response Resources (DRR) participating in the energy market.
Proposals to Prevent Market Manipulation or Fraud
CPower fully supports MISO in its efforts to refine its market rules to prevent bad actors from engaging in manipulative market behavior. Below we provide comments on each of the three forms of manipulative behavior and MISO’s proposals to mitigate such behavior.
Payment for Artificial Curtailments
MISO’s proposal to address instances of Market Participants (MP) representing DRRs that, under the current market rules, could receive payment for not actually reducing load in response to Scheduling Instructions from MISO include the following changes:
The first proposed solution to require MPs to submit meter data for all hours may help provide visibility and allow MISO to monitor for potential instances where a DRR may have been offered into the market to provide more load reduction than the resource was capable. However, CPower cautions that this solution should only be pursued if MISO has the systems in place to receive this data via API, and methods to automate monitoring the data for potential instances of manipulative behavior. The increased data submission will increase the administrative burden on MPs (and their designated MDMAs if utilized by the MP) to submit this data on a recurring basis. As the quantity of smaller end use accounts (including residential customers) become able to participate increases, MISO should be cognizant of the scope and scale of the amount of data that must be obtained and submitted as the population of participating accounts grows, and assess whether this solution will be scalable to be effective at monitoring the market behavior it is trying to protect against versus it becoming a potential barrier to participation.
The second proposed solution is to require MPs to submit an executive attestation that the load reductions reported were actually achieved may also prove to be burdensome, depending on the frequency a given DRR clears in the market and/or is dispatched by MISO. It is not clear from the proposal as presented the timing and frequency of such attestations, but should MISO move forward with this proposal, CPower suggests such attestations be required on a quarterly basis, if not annually for those settlements reported in the prior quarter or year.
The third proposed solution to make changes to the DART system to limit offers to be consistent with a DRR’s capabilities should be adopted. Having additional checks in place within the DART that consider a DRR’s operating characteristics and limitations to prevent MPs from entering infeasible offers will help to protect against the manipulative behavior MISO seeks to address, while also aiding MPs representing DRRs from submitting market offers that may have been “fat-fingered” or otherwise inadvertently incorrectly entered.
Inflated Baselines
MISO’s proposed solutions to address potential manipulative behavior to make a DRR’s response appear larger than was achieved include:1) specifying how or when DRR testing must occur, 2) changes to the Calculated Baseline to preclude event hours (rather than event days) from the calculation and/or utilizing an average or minimum of the baseline hours when sufficient data within the 45-day lookback period does not exist to perform the full calculation, and 3) screening offer parameters against those of the resource to check that they are consistent.
Regarding the first proposed solution to specify how or when a DRR tests, CPower requests MISO to provide additional information on what this proposal entails. While at the surface level, this proposal may have merit, but without further detail, it is difficult to say whether we would support this proposal. It certainly makes sense to ensure that testing is conducted under “normal” operating conditions for the DRR and the test requirements align with the services the DRR provides in the market, and not, say, when the sites comprising the DRR take the opportunity to test when they would be reducing their load for other reasons.
MISO’s second set of proposed changes to the Calculated Baseline methodology to preclude only event hours (rather than event days) from the baseline calculation, and when insufficient data is available, to utilize an average or minimum of the baseline hours. The first portion of this recommendation is something CPower would likely support but would like to better understand the proposed redlines to Attachment TT of MISO’s Tariff to effectuate this change before providing support. Regarding the second portion of this proposal, we would like to better understand how MISO plans to use the available data to calculate the baseline before we take a position on whether such a change should be made.
Regarding the third proposal to screen offer parameters for DRRs to ensure consistency with the resource’s capabilities, as stated in our feedback above, CPower supports MISO enhancing its DART system to consider DRR operating parameters and characteristics to prevent infeasible offers from being submitted.
Fraudulent Registration
To prevent instances of MPs registering customers to participate as part of a Demand Resource without their consent, MISO’s proposal is to extend the existing requirement applicable to ARCs only to provide the signature pages of the contract with the customer to all MPs. CPower supports MISO in making this requirement applicable to all MPs.
Additional Proposed Tariff Requirements
CPower would like to better understand what MISO’s proposal is for the changes it may seek to make within Module D of its Tariff regarding Reference Level calculations for DRRs, as well as potential changes to the thresholds for economic withholding and uneconomic production. Without further information regarding this proposal, CPower cannot say whether it may support or oppose this proposal.
MISO has also proposed implementing an offer floor for DRRs offering energy into the DA and RT markets to be at least the Net Benefits Price Threshold (“NBPT”) applicable during a given month. Seeing as the NBPT is currently applied during the settlement process, and it is possible that a MP may not be compensated for its load reduction if scheduled if the offer and/or LMP clearing prices are below the monthly NBPT, applying this as an offer floor as part of the DART changes to ensure a DRR’s offers are consistent with its capabilities and operating parameters makes sense to pursue.
Other Considerations for DR
Of the other considerations noted in MISO’s presentation, CPower supports MISO looking into raising or eliminating the current 40% cap on DRRs providing Spinning Reserve Service. In addition to the issues MISO identified and is seeking to address through its proposed market rule changes, MISO should also consider including as part of its planned comprehensive DR workshop the issue of how it handles duplicate registrations for the same end use customer account when more than one MP seeks to register that customer.
Conclusion
CPower appreciates the opportunity to comment and looks forward to further discussion of this topic in the stakeholder process.
Respectfully,
Peter Dotson-Westphalen
Sr. Director, Regulatory & Government Affairs
CPower
Peter.D.Westphalen@CPowerEnergyManagement.com
781-214-7523