RASC: LMR Reforms (RASC-2019-9) (20240923)

WPPI offers the following initial comments in response to MISO’s LMR presentation at the September RASC meeting.  We may refine and supplement these for the November 25 deadline, but would like to share our initial thoughts with MISO without undue delay.

To begin, we stress the importance of MISO recognizing that LMRs include a variety of resource types—large and small, sophisticated and less so, able to respond quickly and not, able to respond a large number of times and not, with a variety of meter-equipment arrangements and variation in their forecastability.  The MISO footprint benefits from the availability of all these resources and MISO should seek to accommodate individual resource characteristics to the extent reasonably possible, rather than imposing arbitrary requirements on large swaths of LMRs and expecting them to be able to interact with MISO operators with the sophistication of a dispatchable generator in the energy market.  We address specific topics from the September RASC meeting below.

Accreditation of Demand Resources, Non-Intermittent BTMG, Intermittent BTMG, and AME Generation Resources  

1. MISO proposes to accredit resources using a complex system based on offers and Attachment TT capability estimates.  We have several concerns about this approach.
1. MISO proposes a relatively intricate accreditation approach that appears much more complicated than necessary and yet fails to ensure proper accreditation.
2. All that is required for proper accreditation of DR LMRs—or DRRs—is consistency between the accreditation methodology and the way that the Load Obligation is calculated for the corresponding load.  This is something that can be readily achieved without the complication that MISO proposes, and that does not appear to be accomplished by MISO’s proposal, since MISO does not propose a corresponding approach for calculating LSEs’ capacity Load Obligations.
3. MISO proposes an approach that partially aligns with the Schedule 53 approach.  Consistency is a worthwhile goal but differences in resource characteristics can justify differences in accreditation methodology.
4. Notably, Schedule 53 Resources generally have relatively constant expected capability when in service, but are prone to long planned and forced outages, whereas Demand Resources will in many cases have capability that varies (possibly in a manner correlated with overall system demand), but are much less subject to long outages.  Thus an adequate sample size is important for Schedule 53 Resources while, for Demand Resources, sampling during periods consistent with expected deployment conditions—and avoiding other conditions—is most important.
5. MISO proposes that accreditation be based on reported availability during season-specific Capacity Advisory conditions with a one-year lookback period, with previous years used to the extent required to reach 65 hours.  This appears problematic.  We note that Capacity Advisories occur only roughly every other year in each of the fall and spring seasons, sometimes in only a portion of the MISO footprint.  This means MISO is likely to have to use a number of past years to achieve an adequate sample size, even where older data may no longer be a good guide to current capability.  In addition, as discussed at the September RASC meeting, capacity advisories sometimes span multiple days, even when many hours in this period do not actually involve capacity-shortage risk, and low-risk hours may not be representative of DR LMR capability during actual risk hours.  These considerations point to the need to revise MISO’s proposal to focus on low-margin hours and exclude low-risk hours.
6. The fundamental principle underlying MISO’s Resource Adequacy efforts in recent years is that resources should be accredited on the basis of their contribution at the time of MISO need.  Proposing to use low-risk hours during multi-day capacity advisories for accrediting LMRs violates this principle.
7. We understood MISO’s September presentation to propose accreditation derates resulting from zero availability for hours in which MISO calls for a resource to be in effect sooner than its registered lead time would allow.  We do not support this approach.  MISO should manage LMR lead times as it does for Capacity Resources, by committing them early enough to make effective use of them despite their notification lead times.  We note also that many Max Gen Events are declared for longer than four hours, in which case shorter-lead-time LMRs may be called upon to provide support in the first part of the event, to be superseded by longer-lead LMRs that can provide needed support through the end of a longer event.

Availability Requirements  

1. MISO proposes to impose penalties on DR LMRs whose reported availability is outside the bounds specified by MISO.
1. We note that MISO began the discussion of the last six months by arguing that LMR availability reporting was deeply flawed, only to concede under questioning at the September RASC meeting that this conclusion was based on an insufficiently detailed review of the data, and that in fact such problems are much smaller than MISO previously represented.  We know also that improvements in the reporting interfaces can further address accuracy.
2. We recognize that accurate information is important to MISO operators, but this penalty structure appears to us the wrong way to address the issue.
3. MISO faces significant uncertainty in the performance of conventional resources, and the aggregate uncertainty around large groups of LMRs should be expected to be relatively narrow—and MISO has not demonstrated otherwise.
4. MISO should be largely indifferent to forecast error for DR interruption capability to the extent that over-forecast of future interruption capability corresponds to below-expected future baseline demand, and vice versa.
5. It appears to us that the proposed detailed offer-accuracy compliance regime, with penalties, applicable to all LMRs, is unnecessarily burdensome for both LMR owners and MISO.
6. It is reasonable for MISO to require larger DR LMRs to provide real-time SCADA data on current demand levels.
7. MISO should establish a size threshold below which this is not required, for which aggregate uncertainty is small in comparison with all the other sources of uncertainty confronting operators.
8. DR LMR owners should not be required to make financially binding forecasts of interruption capability, though it is reasonable to request best-estimate forecasts for informational purposes.
2. MISO proposes to make all LMRs with notification times exceeding 30 minutes eligible for deployment at Max Gen Alert.
1. We understand that MISO is focused on dividing LMRs into two types, but this does not mean that all longer-lead LMRs need to be eligible for deployment at the same point in the emergency procedures.  Grouping one- or two-hour LMRs with six-hour LMRs fails to distinguish adequately between these resources and—critically—fails to provide an adequate incentive for LMRs to reduce notification time—an incentive MISO has repeatedly stressed it wants to create.  MISO should employ a graduated system of earlier deployment eligibility for longer-lead-time LMRs.
2. The data set MISO appended to the September RASC presentation in its September 25 posting is more useful than the summaries previously presented, but falls short of what is necessary to fully assess the reasonableness of MISO’s proposal.  We would ask MISO to seek to provide data for years prior to 2020, to include not only the start time but also the stop time of the declaration periods, and to indicate the applicable LBAs.  We note that MISO already provides most of the information in question, on OASIS, at https://www.oasis.oati.com/woa/docs/MISO/MISOdocs/Capacity_Emergency_Historical_Information.pdf, but that this posting does not include the time at which the notification was issued.  Simply updating the current posting to include the issuance time would suffice for the purposes of the current LMR discussion and would provide a more informative posting for any other users of this data.
3. MISO says at slide 2 of its September 23 presentation that its proposal ensures “reliable and efficient grid operations during emergency conditions.”  We are not convinced that MISO’s proposal will lead to efficient outcomes.  Specifically, given that Max Gen Alert precedes emergency pricing, emergency ranges, curtailment of non-firm exports and import scheduling for cleared External Resources, we see a significant risk that LMRs will be deployed in conditions where prevailing LMPs are far lower than the cost of emergency resources.  This is also a significant concern because low prices are an indication that an excessive quantity of LMR capacity has been deployed, and this will tend to drive high-cost LMRs to cease participating, which would do significant damage to reliability in the MISO region.
4. Some longer-lead-time BTMG LMRs have restrictions in their air emissions permits that allow deployment only during specified emergency conditions.  MISO’s deployment regime needs to account for these constraints.

Measurement and Verification

1. MISO says (at slide 32) that “The underlying assumption to this [firm service level] methodology is no longer valid” but fails to substantiate this claim.
1. MISO suggests that firm service level (FSL) will no longer work as the critical hour moves away from the peak hour, but FSL can be applied under any rules for identifying the critical hour.
2. Under MISO’s proposal, the determination load obligation and LMR accreditation are no longer aligned—this is the invalid methodology, not an FSL that explicitly aligns these.
3. To the extent MISO’s concern is reporting of RT availability, that is a distinct issue that should not be the basis of eliminating FSL.

Testing

1. MISO ties together testing with performance in response to a MISO call.  This appears conceptually flawed.  The proper purpose of testing is to determine capability, whereas it is always possible that future performance may fall short of capability, and this should be dealt with via future accreditation consequences or other penalties rather than testing requirements.

Meter Data Requirements

1. MISO should allow LMR data to be in a manner consistent with how LSEs report meter data for Actual Energy Withdrawals today.
1. There is no evident basis for eliminating this option.
2. MISO proposes to require 5-minute data for Type II LMRs
1. This appears to be a shorter interval than necessary.  MISO should allow 15-minute meter data for these resources, as it appears this would have always been adequate to demonstrate desired performance in past events, which have nearly always been called on the hour.

Terminology

1. MISO says, at slide 7, that in the proposed future state “Both DRR and LMR will be treated as Planning Resources.”  We note that, under the existing tariff, but DRR and LMR are already included in the definition of Planning Resources.
2. MISO appears to want to abandon the notion of availability reporting for LMRs in favor of “offers.”  We would suggest retaining offers for price-based submittals, with LMRs continuing to report availability.

American Municipal Power (AMP) appreciates the opportunity to provide feedback on MISO’s LMR Reforms proposal.

AMP supports and signs onto WPPI Energy’s previously submitted comments in response to MISO’s LMR presentation at the September RASC meeting.

MPPA finds one aspect of MISO’s Accreditation of Demand Resources and Non-Intermittent BTMG to be unreasonable. That aspect is assigning 0 accreditation to hours of deployment that do not respect the notification time of the resource (“20240923 RASC Item 02a LMR Reforms (RASC-2019-9)649248” slide 23).

First, MISO is the only entity with the information and resources to optimally prepare for tight margin and emergency system operating conditions.  One of the four pillars of MISO’s Reliability Imperative is Operations of the Future.  As MISO has emphasized repeatedly, the factors that drive system reliability are changing more rapidly than originally anticipated.  As owners of resources currently under the rubric of Load Modifying Resources do their part to adapt to the challenges, MISO must do its part.  Given MISO’s proposed Planning Year 2028-2029 implementation of the LMR changes, MISO must step up to improve its operations in order to fully utilize DRR and LMR Type I while respecting their notification times.

Secondly, even if MPPA accepted MISO’s proposed logic (which it does not), assigning 0 accreditation to the hours between notification and the start of the event (Market Hours 2:00 PM and 3:00 PM in the example) is patently unfair.  MISO’s proposed logic would justify assigning 0 accreditation starting with the event (Market Hours 4:00 PM and 5:00 PM).

MPPA urges MISO to reconsider this aspect of their proposed LMR changes and modify it to be more reasonable.

Dairyland Power Cooperative (DPC) appreciates the opportunity to provide feedback on MISO's LMR Reforms proposal.

DPC supports and signs onto WPPI Energy's previously submitted comments in response to MISO's LMR presentation at the September RASC meeting.

Alcoa Power Generating, Inc. (APGI)

Feedback

“LMR Reforms (RASC-2019-9) (20240923)”

October 25, 2024

During the October 09, 2024, Resource Adequacy Subcommittee (RASC) meeting, MISO requested feedback on their final proposal to reform the accreditation process for Load Modifying Resources (LMRs).[1]  

As a MISO Member, MISO Market Participant, and Load Serving Entity with LMRs registered and participating in MISO, Alcoa Power Generating Inc (APGI) has specific interests in the accreditation process for LMRs.

APGI offers the following feedback to MISO’s proposal:

• LMR-Type I and LMR-Type II Options: MISO has proposed to split the current LMR participation design into two participation options. APGI is supportive of this direction and agrees with MISO that this proposal provides a balance between those resources that are only able to respond during critical system emergencies and those resources that can respond earlier in the system emergency process. This introduction of the LMR-Type I option also gives more flexibility to MISO Operations to access some LMRs before the EEA-2.
• Response Requirement: MISO has proposed an unlimited number of responses from all types of LMRs. As a market participant that has provided LMR interruptions from its manufacturing facilities in the past, APGI is concerned with this requirement and how it would potentially impact Demand Response across the entire MISO system. This requirement makes the quantification of risk to Demand Response participants nearly impossible to determine. Without a backstop on the number of requirements and no energy payment for deployment response, a resource could be called dozens of times without any mechanism to balance the impact on the customer. This uncertainty is of particular concern to some large industrial consumers like APGI who are significantly impacted by interruptions. As a practical example, APGI must rationalize participation benefits with participation costs to decide whether it will continue to participate in the MISO PRA. For decades, APGI has supported grid reliability and has the capability to continue to provide emergency response in the future, but it is critical that the business impact can be quantified for business planning purposes and to ensure incentives for any future participation.
• Energy Compensation for LMRs: MISO has proposed that there will be no Energy payments for deployment of LMRs. APGI urges MISO to consider adding Energy payments during deployments (in much the same way that traditional generation resources receive an Energy payment when called) to offset the business impact and to balance participation uncertainty and other design changes proposed by MISO. The energy compensation could also be a viable balance for the proposed removal of the EDR option.

• Emergency Demand Response (EDR): MISO has proposed to eliminate the opportunity for resources to register as EDRs. Although, APGI has not used this option, the EDR would be a potential option in the future that APGI would consider. EDRs enable a customer to respond during an emergency and receive compensation for the response. With the lack of any energy compensation for an LMR, the EDR mechanism should remain available as a participation option. With MISO’s change to an unlimited number of responses, the option to receive an Energy payment as an LMR in the event of an activation allows customers some mechanism to recover real costs of the impact of a deployment and to balance the risk uncertainty with the unknown number of responses and the subsequent financial impact.

While MISO has noted that a DRR receives an Energy payment, registration as a DRR in the MISO Market may not be a viable option for some customers because some customers are only permitted (by either the state or federal agencies) to respond to “emergency conditions.” Responding to a “market signal” would not be considered an “emergency condition.” Additionally, the registration and participation requirements for a DRR are much more significant than for an LMR. Again, MISO is proposing a solution that sounds reasonable but may not be viable for some market participants today. 

• Firm Service Level (FSL) Customers: FSL customers provide valuable reliability services to MISO and should be accredited appropriately. MISO has indicated in the “Measurement and Verification” portion of the MISO presentation that an FSL customer could get appropriate accreditation. Unfortunately, there was not time in the RASC to discuss this topic in sufficient detail to gain a clear understanding of MISO’s intent.

APGI requests that MISO develop examples of the FSL accreditation process and address whether MISO will treat a resource that is already at reduced load as a self-scheduled resource for accreditation purposes. If MISO plans to accredit an FSL for their self-curtailed load, then APGI would support this treatment, but MISO should explicitly address this issue. 

• 24-Hour Separation Rule: MISO has stated that it will not be utilizing any separation time between activations of LMRs. Taken to the extreme, this could mean that an LMR is required to respond many times within a single day or even sequentially across several days. This is another concerning aspect of the MISO proposal because it eliminates any certainty on how to evaluate risk of activation for consumers like APGI. As mentioned above, this would be another rationale for the inclusion of an Energy payment to balance the uncertainty and inability to regulate how a resource is utilized.
• Testing Criteria:  APGI supports MISO’s proposal to allow a deployment to count as a test and supports the provision for opt-out of testing for an LMR-Type II. For large industrial consumers like APGI, the cost of an interruption is high and should not be performed unless an emergency exists. MISO has also stated that an LMR-Type I will only be tested if requested by MISO and if no deployments have occurred in the year. In the details of MISO’s presentation, MISO states that the tests will be “MISO initiated.” More details are needed on the testing procedure and on whether MISO will be utilizing the “available” capacity in the DSRI for the test response expectation. APGI requests that MISO provide some test examples to illustrate test expectations from MISO for customers that are not operating at full demand for a given day.

APGI appreciates the opportunity to provide feedback on this issue.

If there are any questions or comments, please feel free to reach out to:

Steve Dowell

ESS LLC, Alcoa Power Generating Inc.

(812) 853-1135

Steve.Dowell1@alcoa.com  

DeWayne Todd

DDT LLC

(812) 573-8052

dewayne.todd1@alcoa.com

Thank you for this opportunity to provide feedback on MISO's LMR proposal.  IMEA shares the concerns expressed in MPPA's feedback on this topic.

WEC Energy Group continues to support a thorough review of LMR accreditation and operational access to improve the efficient procurement and operational use of LMRs, consistent with MISO’s Reliability Imperative.  MISO’s Reliability Imperative is comprised of four pillars, including Operations of the Future.  We believe enhancements to operational tools and procedures will significantly improve the visibility and viability of LMRs during high-risk periods.  More time and effort on enhancements to operational tools and “Operations of the Future” is needed prior to filing LMR reforms – the two are complimentary.

We continue to have significant concerns with MISO’s proposal for LMR accreditation and operational access.  The publication of the LMR white paper on the same day as the last RASC meeting, October 10, 2024, does not provide stakeholders with enough time to digest the 32 page document, educate others within their organizations (including executive teams), conduct internal meetings, educate Demand Response customers, seek feedback internally, seek feedback from Demand Response customers, ask follow-up questions of MISO, and develop formal feedback by the October 25 deadline.  The compressed schedule with an anticipated FERC filing by the end of the year does not provide stakeholders with enough time to conduct their internal and external outreach in order to educate their Relevant Electric Retail Regulatory Authorities (RERRAs) on how the proposal will affect capacity needs and retail rate design.

LMR reform is a significant undertaking with broad reaching impacts.  WEC Energy Group requests that MISO delay the filing of its LMR reforms with FERC by at least 4 months to allow more time for stakeholders to conduct their internal and external outreach and to develop meaningful input.

Given only 15 days between publication of the October 10 white paper and the October 25 due date for comments, WEC Energy Group is still digesting the proposal.  We further note that comment development is hampered by the Annual OMS Meeting on October 23 and 24, which is largely focused on Resource Adequacy issues and attended by many of the same RASC stakeholders.  We provide the following comments based on a very preliminary review:

1. The LMR proposal does not provide enough granularity to recognize Demand Response with lead-times between the two book-ends of LMR Type I and Type II (6 hours and 30 minutes, respectively).  We believe that another LMR Type with lead-times up to 2 hours and deployed at MaxGen Event Step 1 is necessary to recognize the wide array of Demand Response programs.
   1. For example, an interruptible customer that can respond within 2 hours (but not within 30 minutes) is currently subject to an average deployment of about once every four years.  Registering that same customer as an LMR Type I will increase the number of deployments to an average of 3 or more times per year.  Based on early discussions with one of WEC Energy Group’s interruptible customers, the increased risk of the number of deployments per year may consume all of the savings associated with the interruptible program.
      1. In round numbers, the customer has 8 MW of interruptible load.  In 2023 the customer saved about $500k by taking service under the interruptible rate.  This equates to a savings of 62,500/MW-yr.  Depending on whether or not they can make up production to fulfill orders on time, their cost of lost production is as high as $64,000/hr or $8,000/MW-hr for 8 MW of curtailment.  Assuming a 1 hour response time, 1 hour to come back up, and 4 hours of interruption, the cost of a single 4 hour interruption is as high as $48,000/MW-hr.  If MISO calls for 6 hours of interruption (for a total of 8 hours lost production), the cost is $64,000/MW, which consumes all of the savings in a single deployment.
         
         
2. MISO’s proposed LMR accreditation (Demand Response in particular) during Capacity Advisory Hours is largely based on Attachment TT.  More time is needed to fully understand the application of Attachment TT to the accreditation of Demand Response, especially for Firm Service Level customers.
   
   
3. MISO’s proposal to accredit LMRs based on their performance during Capacity Advisory Hours during a one-year look back period may have unintended consequences, especially during those historic seasons with little or no Capacity Advisory Hours.
   
   
4. MISO’s accreditation proposal assigns a capability of 0 MW to Demand Response for hours in which MISO initiates deployment sooner than its registered response time would allow.  We do not support this approach.  We prefer that MISO improve LMR deployment via the “Operations of the Future” pillar of the Reliability Imperative.
   
   
5. We agree that accurate LMR availability information is critical to ensuring the reliable and efficient operation of the Bulk Electric System (BES), which is why we believe the “Operations of the Future” pillar of the Reliability Imperative is a crucial component of LMR reform.  MISO’s proposed tolerance band and penalty structure fails to align the “Market Reforms” and “Operations of the Future” pillars.
   
   
6. We have not had time to determine if MISO’s meter data requirements are feasible with existing infrastructure and what changes are needed (including the time to make those changes).
   
   
7. An annual test for LMR Type I Resources that have not been deployed during the previous Planning Year will negatively impact the economics of interruptible rate programs and require changes to those programs.  Much more time is needed to understand these impacts and to work the RERRAs on possible changes.

Clean Grid Alliance (CGA) appreciates this feedback opportunity.  CGA generally agrees with the questions and suggestions submitted by WPPI, MPPA, and WEC regarding MISO's proposed LMR reforms (as well as consistent ALCOA comments).  In particular, CGA joins them in encouraging MISO to ensure that MISO's Operations of the Future fully and efficiently accommodate capacity market participation by any potential LMRs (and potential Planning Resources more generally) that have incremental capacity value.  MISO's Operations of the Future should capture efficiency and reliability gains from the variety as well as the scale of potential market resources.

Arkansas Electric Cooperative Corporation (AECC) appreciates the opportunity to comment on MISO proposals to modify requirements for LMRs.

If MISO moves forward with all its proposals, AECC fears reliability will be impacted negatively, as existing LMRs will convert to firm load, exacerbating the need for new capacity resources.

Regarding penalties on LMRs whose reported availability is outside the bounds specified by MISO, AECC’s LMRs include ones with highly variable loads including intra-hour and yet are capable of curtailing when needed.  Penalties could force conversion to firm, exacerbating the need for new capacity resources.

AECC asks MISO to please consider the following as an alternative to penalties:

1. Use real-time load (less amounts designated as firm service level) as the baseline
2. Provide option for the market participant to provide real-time SCADA metering on each of its LMRs directly to MISO to avoid penalties.
3. Provide the flexibility in the reporting interface for market participant to provide the real-time metering of each of the LMRs through the reporting interface (including field shown with amount designated as firm service level).

AECC repeats its comment previously provided that, while these industries recognize that in return for a reduced electricity rate, they can be curtailed prior to firm customers, an ability for MISO to curtail them an unlimited number of times is not acceptable and will certainly force them to convert to firm.

Advanced Energy Management Alliance

MISO Resource Adequacy Sub-Committee (RASC)

“LMR Reforms (RASC-2019-9) (20240923)”

October 25, 2024

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Resource Adequacy Sub-Committee (“RASC”) on the feedback request made by MISO at the October 9, 2024, meeting of the RASC.[2] AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy resources. AEMA members support the beneficial incorporation of DR and distributed energy resources (“DER” or “DERs”), including advanced energy management solutions, into wholesale markets as a means to achieving electricity cost savings for consumers, contributing to system reliability, and ensuring balanced price formation. These comments represent the collective consensus of AEMA as an organization, although they do not necessarily represent the individual positions of the full diversity of AEMA member companies.

At the October 9^th meeting of the RASC, MISO presented their “final design” proposal for Load Modifying Resource (LMR) accreditation reform. AEMA appreciates the positive changes that MISO has made to its original proposal. AEMA is conceptually supportive of MISO’s proposal to create two participation options for LMRs in the form of either an LMR-Type I or an LMR-Type II. This expansion of options appears to be a reasonable approach to give MISO Operations access to some resources ahead of EEA 2 events, while preserving a participation option for those resources only available in extreme emergencies. 

AEMA is concerned about multiple elements of this complex proposal by MISO. The general concerns include the following:

• Unlimited Response Requirement: MISO has proposed an unlimited number of responses from all types of LMRs. As previously stated by AEMA and many other stakeholders, this aspect is problematic because it makes the quantification of risk nearly impossible when working to understand participation obligations for LMRs. Without any backstop on the number of responses required and no energy payment for deployment response, a resource could be called dozens of times without any mechanism to balance the impact on the customer. This uncertainty is of particular concern to some large industrial consumers who are significantly impacted by interruptions. Many of these resources have supported grid reliability for decades and can continue to do so on a limited basis but without some balance to the potential impacts, they may be forced to stop participating in supporting grid reliability. 
  
  
• Lack of Energy Compensation for LMRs: MISO has proposed that there will be no Energy payments for deployment of LMRs. As mentioned above, AEMA encourages MISO to consider the addition of an Energy payment during deployments (in much the same way that traditional generation resources receive an Energy payment in the same situation) to offset the participation uncertainty and other design changes proposed by MISO. 

While some stakeholders have suggested that LMRs should push this risk factor into their capacity offer in an attempt to capture the deployment risks in their capacity revenues, this suggestion creates concerning inefficiencies in the capacity market pricing. The most efficient market results occur when resources can offer and clear in the markets at offers that reflect their actual costs as much as possible. Adding an offset to the capacity offer for “potential interruptions” would not reflect actual costs of offering capacity independent of the variable event impacts. Adding an energy payment would separate the two impacts and more closely reflect traditional generation that separately receives capacity revenue and energy revenue independently when cleared in the different markets.  

• Elimination of Emergency Demand Response (EDR): MISO has proposed to eliminate the opportunity for resources to register as an EDR. AEMA does not support this change. EDRs provide a customer with an option to respond during an emergency and receive compensation for the response. AEMA believes that with the lack of any energy compensation for an LMR, the EDR mechanism should remain available as a participation option. With MISO’s change to an unlimited number of responses, the option to receive an Energy payment in the event of an activation allows customers some mechanism to recover costs of the impact of deployment and balance the uncertainty with the actual number of responses and the ensuing financial impact. 

While MISO has noted that a DRR receives an Energy payment, registration as a market resource may not be a viable option for some customers because the customers are only permitted (by either the state or federal agencies) to respond to “emergency conditions.” Additionally, the registration and participation requirements for a DRR are much more significant than for an LMR. Again, MISO is proposing a solution that sounds reasonable but may not be legal for some market participants today or may have inordinate costs associated with Day-Ahead and Real-Time market participation.  

• Treatment of Firm Service Level (FSL) Customers: AEMA believes that customers that can curtail to a firm service level provide valuable reliability services to MISO and should be accredited appropriately. During the October 9^th meeting of the RASC, there was significant discussion of FSL customers and confusion over what MISO is proposing. MISO’s comments focused on “load obligation determination” and the presentation from MISO stated that FSL is not “straightforward.” Multiple stakeholders challenged the MISO statements, particularly on the “straightforward” aspect. Despite these disagreements, MISO has indicated in the “Measurement and Verification” portion of the MISO presentation that an FSL customer could get appropriate accreditation. Unfortunately, there was not time in the RASC to discuss this topic in sufficient detail to gain a clear understanding of MISO’s intent. 

AEMA requests that MISO develop examples of the FSL accreditation process and addresses whether MISO will treat a resource that is already at reduced load as a self-scheduled resource for accreditation purposes. If MISO plans to accredit an FSL for their self-curtailed load, then AEMA would support this treatment, but MISO should explicitly address the issue to provide clarification.  

• Elimination of 24-Hour Separation Rule: MISO has stated that it will not be utilizing any separation time between activations of LMRs. Taken to the extreme, this could mean that an LMR is required to respond many times within a single day or even sequentially. This is another concerning aspect of the MISO proposal because it eliminates any certainty on how to evaluate risk of activation for consumers. As mentioned above, this would be another rationale for the inclusion of an Energy payment to balance the uncertainty and inability to regulate how a resource is utilized.
  
  
• Testing Criteria:  AEMA supports the MISO proposal to allow a deployment to count as a test and the provision for opt-out of testing for an LMR-Type II. MISO has also stated that an LMR-Type I will only be tested if requested by MISO and if no deployments have occurred in the year. In the details of MISO’s presentation, MISO states that the tests will be “MISO initiated.” AEMA requests more details on the testing procedure and clarity on whether MISO will be utilizing the “available” capacity in the DSRI for the test expectation and evaluation. MISO should address how a resource that is at “not peak” operations, as reflected in the DSRI, will be treated and accredited during a test.
  
  
• Four Hour Minimum Response: MISO has stated that a resource must be capable of responding for a minimum of 4 hours to receive capacity accreditation. MISO should examine options for response of shorter periods, with a potential reduction in accreditation. 
  
  
• Tolerance Bands: MISO has proposed establishing a tolerance band in the real-time deployment capabilities of LMRs. This bandwidth tolerance is logistically concerning for AEMA, because it creates a potentially onerous requirement for customers like large industrial loads. While the upper bound is not unreasonable, the lower bound is unnecessarily arduous. Consider a large load that is restoring operation to a facility or even a specific production line. This start-up process is often difficult to predict, and MISO’s proposal would penalize a resource for the inability to predict to within a very tight margin. Given that DRs are subject to withholding examination by the IMM, the lower limit is not necessary. AEMA urges MISO to remove the lower bound concept and accredit these resources based upon the stated availability as long as it is below the upper bound.

AEMA appreciates MISO’s consideration of these comments as part of the examination of resource accreditation issues within MISO. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to discuss this with AEMA members.

Respectfully Submitted, 

Katherine Hamilton
Executive Director, Advanced Energy Management Alliance
Katherine@aemalliance.org
202-524-8832

or

DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052

MidAmerican Energy appreciates the opportunity to provide feedback on LMR Reforms (RASC-2019-9) (20240923).

MidAmerican would like MISO to respond why an LMR Type II can’t have a 120-minute notification requirement like PJM’s current process. Has MISO reached out to PJM to see what they are doing that MISO could be doing and sharing best practices for reliability?

In general, MidAmerican understands the reforms that MISO is recommending but the following things seem unreasonable:

• A DRR that clears in the PRA will have a must-offer in the day-ahead market AND have a max response time of 6-hours. A normal generator can have less than 24 hours without any ramifications, so this is discriminatory.
• Based on history, the short notification times would not have been needed in the summer for an LMR Type-II. If MISO is unwilling to go to 120-minute notification times year-round, they should consider doing it in the summer until needed.
• Assigning 0 accreditation to the hours between notification and the start of the event is illogical, unfair and unproductive. If a resource has a 4-hour notification and the event lasts 3 hours, requesting that the resource immediately respond is unreasonable. A generator with a long notification time is not treated the same and this is discriminatory.
• Being penalized for over-responding in the name of market efficiency flies in the face of good utility practice. When MISO gets to maximum generation levels, the focus should be on reliability and no longer on market efficiency. One example, where this is illogical is a curtailment customer that has a block capability of 70 MW, but the MISO request is for 50 MW.
• A related issue where MISO should provide clarity is on the ability to choose how the MP can deploy LMRs. Currently, MISO will provide the amount MWs required, and the MP can deploy as they see fit. Once MISO is using the location information, will MISO ask for all or nothing at a given location? It is unclear how MISO will handle this. Please explain.
• Given that LMRs, especially demand response, are typically industrial customers that are curtailing load, it makes sense that a customer like this would not want to curtail frequently, especially since they are not getting energy revenue. Although an LMR does have reliability value, an LMR is less reliable than actual generation, despite it being treated equally. If MISO were to implement these reforms, it immediately becomes an equity issue. The more LMRs that the system is relying on, the more likely that LMRs will be called upon. If the magnitude of the LMRs isn’t evenly distributed between load serving entities, it becomes unjust and unreasonable and at some point, and it becomes a reliability issue. Like the capacity import limit that is a consideration for the capacity auction, there may be a reliability threshold limit for LMRs. MISO should do an analysis on the magnitude of LMRs (e.g. % of total Capacity Resources in a Local Resource Zone) that causes a reliability issue. The entire DLOL construct is around identifying the value of capacity so by not doing that with LMRs in some fashion other than looking backward does not seem reasonable.

MPPA also supports WPPI's and AMP's feedback.

MISO’s LMR proposal is flawed because it is likely to sour our customers from participating and because MISO is trying to treat all LMR programs as a single unit generator, instead of recognizing them for what they truly are – an aggregated group of individual customers with varying sophistication, process response times, and participation vulnerabilities.

MISO should make all of the following changes to its proposal to protect the MW capabilities currently enjoyed by MISO - even if less than ideal on limited occasion, from an operational perspective:

• LMR Type I should be deployed at EEA2 as opposed to MaxGen alerts.
• The “no deployment limits” should be dropped.
• The near real-time hourly capability offer requirements and the proposed penalties for offer bound violations should both be dropped.
• The 2028 implementation should be delayed to 2030 and MISO should stop “stacking” construct changes in the same year, and instead should phase-in changes in a stair-step manner over time.

We are not satisfied that MISO has truly listened to stakeholder concerns and refined its proposal in response. MISO needs to continue to whittle away at its proposal to get to a settlement point that no one likes but everyone can live with.

Wabash Valley Power Alliance (“WVPA”) appreciates the opportunity to comment on the MISO Load Modifying Resource (LMR) Reform proposal updates as shared during the September 23, 2024, and October 9, 2024, Resource Adequacy Subcommittee meetings.

Accreditation of Demand Resources, Non-Intermittent BTMG, Intermittent BTMG, and AME Generation Resources

WVPA understands what MISO is trying to achieve, but the proposal terms for accreditation are far too complicated. What is missing in this discussion is that LMRs are not energy industry insiders. They do not primarily produce energy and/or capacity as their main product. Rather, they consume energy to produce products and services which they sell, but for a price are willing to curtail such production on a limited basis so long as their main source of business remains intact. The final proposal must, in practice, be an uncomplicated concept with an easily explainable process that stakeholders can clearly communicate to interested parties, whether they are commercial, industrial, agricultural or consumer in nature. If it is not, participation will be viewed as a risk to the primary revenue source that outweighs the benefit. Additionally, uncertainty of capacity advisory hours year to year causes accreditation risks to market participants, as they can only offer resources into the auction based on historical data, which is inherently flawed during this time of rapid industry change.

Availability Requirements 

While WVPA recognizes the need for LMRs that can respond very quickly to resolve an emergency. Prior to instituting the 30-minute response time, MISO should consider a test to determine if a 30-minute response is achievable even during non-emergency conditions, given the multiple layers of notifications that may have to occur between the MISO EEA 2 notification and the expectations that resources are online 30 minutes later.  MISO needs to understand that these communication channels will vary company to company and will vary further resource to resource.

Further, requiring LMR – Type II resources to respond to all deployments, including more than one event in a 24-hour period is unreasonable and will drive all but residential programs to LMR – Type I registration. Simply put, MISO is asking a commercial or industrial load to accept the risk of a curtailment, then after the end of the curtailment receive another curtailment order before they can achieve a cycle of production. This would be a non-starter for most businesses.

In the Load Modifying Resource Reforms Draft White Paper Version 1 (“White Paper”), (page 16 paragraph 4), when referencing the proposed removal on the limitation on the number of deployments within the Season and eliminating the 24-hour separation period, MISO notes it “…does not expect the historic numbers of deployments for LMR – Type II resources to increase but has found that these operational restrictions have hindered the effective usage of these resources.”  All signals from MISO, especially the Reliability Imperative, indicate that LMR deployments will be rising. The referenced historical data is no longer the best indicator of future load and capacity margins, at best it is a floor value of potential curtailments. Given that expectation, commercial and industrial LMRs will be viewing the decision to participate in the program from a purely economic perspective and be unlikely to view the potential for unlimited interruptions to be worth the benefits proffered by LMR participation. To put a finer point on it, WVPA believes the complexity being added to the process as referenced above and the uncertainty will result in a potential loss of 50% of our LMR participants. Anything close to a proportional drop in participation from other member territories is a loss that the market cannot bear at this time, in view of other constraints.

Measurement and Verification

MISO must provide more detail regarding the proposed modification of the Measurement & Verification options in Attachment TT, as referenced in the White Paper (section 2.7 paragraph 2). Please provide a practical example using data as suggested in Suggestions for Enhancement to Current Proposal Item #2” below to help stakeholders visualize the impact of those modifications.

Suggestions for Enhancement to Current Proposal

1. We agree that real-time availability data is needed. However, MISO’s overarching premise for this proposal is that a lack of incentives or penalties is the basis of the current unavailability of resources in emergencies. Based on discussions during stakeholder meetings, MISO may not have an accurate view of available resources. Some entities noted that their numbers did not match what was in the DSRI tool. WVPA recommends providing DSRI tool training in the near-term to ensure market participants are entering data into the tool correctly, so that MISO has an accurate view of available resources.
2. We recommend that MISO identify a group of capacity advisory hours per season based on a 3-year rolling history and publish this to allow market participants to estimate capability.
3. Since LMR-I may use hourly meter data, the test period for these resources should be a minimum of 1 hour, to show impacts. The currently defined 30-minute parameter is insufficient for this purpose. WVPA also suggests MISO clearly communicate the start time to ensure staff collects accurate data.
4. MISO should afford resources a minimum run time buffer between events, meaning an entity should not be automatically disqualified because of failing to respond to a second event that was too close in time to the first event for an LMR customer to have run through a normal business process. WVPA supports Great River Energy’s recommendations presented at the October 9 RASC meeting, noting that for this example “MISO should allow LMR capability to be zero for the 2^nd event and then the LMR accepts the accreditation hit – rather than being outright disqualified. “
5. The White Paper references that MISO has developed an offer margin that will be measured against the hourly average load profile of a resource. Please detail how MISO will calculate average hourly loads.

Wolverine continues to generally support MISO’s efforts to holistically improve its resource adequacy construct, including its latest efforts on LMR reform. In review of the October 9, 2024 presentation to the RASC, Wolverine offers the following comments:

Support

• The elimination of EDR and the requirement for all energy resources to participate as DRR. This action will also help mitigate the concerns that DR resources could be dispatched uneconomically because the resource will have a cost associated with its dispatch that is directly used in MISO’s resource dispatch stack.
• The one time (1x) per year testing requirement (Slide 40). Testing in the planning year is important to ensure resources can reliably show up when called upon.
• Unlimited calls per season. If resources are getting compensated to be available, they need to be available. Availability at all times is essential to reducing reliability risks and anything less must be reflected in the accreditation.
• Have all registrations managed through one portal to eliminate the MUI, DSRI, and EDR confusion.
• The 6-hour notification time for DRR and Type I LMRs. This provides sufficient flexibility to encourage continued participation of existing LMRs (i.e., not unnecessarily discouraging them from participating).
• The alignment in accreditation between in front of the meter and behind the meter resources.
• Implementation of LMR reform sooner rather than later. For example, a 3-year implementation (e.g., 2028/29) is reasonable and would align with the implementation of the DLOL accreditation.

Concerns

• Type I LMR deployment during the Max Gen Alert phase. Early deployment is important to help proactively plan for a pending crisis rather than retroactively react to a problem. However, deployment of Type I LMRs should align with Tier I of the emergency price floor to avoid price suppression. As proposed, there is a disconnect between LMR Type I deployment during Max Gen Alerts and Emergency Tier I pricing during Max Gen Warnings.
• Outage requirements for BTMG should mirror those of Schedule 53 one-for-one. Routine maintenance is important to maintain reliable performance of BTMG. Coordinating planned outages provides MISO better visibility beyond the one-day horizon and ensures not all resources are targeting the same time periods for planned outages. Additionally, Wolverine supports continued exemptions for distribution or transmission-related outages that might otherwise impact BTMG accreditation. Lastly, MISO’s resource adequacy construct is already complex enough whereby mirroring the outage requirements will create some simplicity via utilization of existing methodologies rather than development of additional methodologies.
• 5-minute data might not be available for some DR resources (Slide 35). Many meters only read on 15 minutes such that shorter intervals would require installing special devices like Remote Terminal Units (RTU) and/or changes to meter configuration and meter data management software (MV90).

Additional Comments

• Similar to Wolverine’s comments on MISO’s PRMR allocation problem statement, there is a disconnect between the Peak Load Contribution (PLC) calculation (one hour per season) and the proposed LMR reform (minimum 65 hours per season). This could be addressed by updating the PLC calculation to reference high risk hours for each season. To provide an example of why this matters, Wolverine has LMR resources (BTMG) that exceed the peak demand of the localized site but are not permitted to backfeed due to the distribution system constraints. If demand was higher during the one hour referenced in the PLC calculation compared to the 65 hours in BTMG accreditation, then the customer would be obligated to pay for capacity twice – once for their on-site capability (more than enough to serve their peak demand) and again for the incremental difference between the PLC value and BTMG accreditation. This disconnect between the calculations creates an artificial cost with no reliability benefit. MISO must consider this real-life scenario as part of its resource adequacy reform so that resources are not unnecessarily discounted.
• Please clarify, would a self-scheduled curtailment or self-scheduled BTM generation be considered a “deployment” be considered a “deployment” (Slide 23).
• It seems a bit counterintuitive that a resource would be penalized for over performing (Slides 32-33). Please elaborate on the justification for this penalty.

American Municipal Power (AMP) appreciates the opportunity to provide feedback on MISO’s LMR Reforms proposal.

AMP shares the concerns expressed in WPPI Energy’s feedback on this topic.

Additionally, AMP offers the following comments for consideration:

• MISO’s proposal requires LMRs to submit 5-minute meter data around deployments. LMRs are not eligible for energy payments so it does not make sense to require 5-minute meter data. Performance has, can be, and should be measured with hourly meter data.
• MISO’s proposed penalty is not just and reasonable. Market resources face an accreditation penalty in future periods for failures to perform. MISO’s rules for LMRs include a future period accreditation penalty plus the existing tariff penalty of a charge per MW not provided priced at the CPnode price of the LMR.
• On slide 26 MISO states non-intermittent BTMG accreditation will use offer data when not deployed and meter data when deployed. It is AMP’s understanding that MISO could partially deploy a BTMG LMR. MISO might only deploy 1 MW of 2 MW available. That appears to penalize the LMR based on the statement MISO included on the slide. MISO should clarify that the performance measure is to the dispatch instruction issued by MISO and not to the accredited value when a BTMG LMR is deployed. Additionally, MISO needs to fix the formula on the slide.
• Unlimited deployments is not reasonable. There should be a cap on the amount of deployments. MISO has not run into the current caps on deployments and deployment hours per year. MISO could reasonably extend the existing caps and have enough hours per year to meet its operational needs. MISO should consider the willingness of retail load to interrupt their operation and MISO should consider environmental limits on BTMG LMRs in setting the number of deployments and hours of deployments per year.

Great River Energy appreciates the opportunity to submit feedback to MISO on RASC: LMR Reforms (RASC-2019-9) (20240923)

In the September 23, 2024, and October 9, 2024, meetings of the Resource Adequacy Subcommittee (RASC), MISO shared updates to its LMR Reforms proposal and sought stakeholder feedback on the following:  

• Accreditation of Demand Resources, Non-Intermittent BTMG, Intermittent BTMG, and AME Generation Resources 
• Availability Requirements 
• Measurement and Verification

Accreditation

Unlimited LMR events, but local contract flexibility - It's a clever technique for sliding accreditation and maximum participation flexibility. GRE likes this.

It is GRE's understanding that there won't be a limit to the number of LMR events called in a season, but MISO won't require the LMR type-I to respond every time but instead will allow an LMR with, say, 50 hours per year of retail contract limitations to only respond up to its contractual limit. And then, if MISO needs this LMR for an 51st hour or beyond, the LMR could then simply set availability to 0 without being disqualified. Then MISO's Event instructions would not ask for any MW from it, but then in the accreditation formula the LMR's next year capacity credit would be derated because it reached it's local retail limit and had 0 capability recorded during a Capacity Advisory hour.

In principle, this provides good flexibility for all types of resources with a range of interest in participation. In a extreme case, this means an LMR which can only respond to 1 event per year may now participate, but they would accept a huge risk for an accreditation derate next year if they get called a 2nd time and don't wish to participate. And of course, an even greater accreditation hit for a 3rd, 4th, 5th event that they choose not to participate in.

This should incentivize market participants to make their LMR assets fully available at all times of need, while providing a flexible option for restrictive LMRs to only participate up to their comfort level and face a requisite penalty in doing so.

It's not clear how MISO will collect and evaluate Meter Data for statistical DLC loads used for computing the capability of the 65 Capacity Advisory hours

For a LMR registered with a DLC Consumption Baseline where interval metered data is not available from the numerous dispersed resources, what data will MISO require for the minimum of 65 capacity advisory hours per season?  

Can an example be provided on determination of capability of a demand resource registered with a DLC Consumption Baseline similar to figure 4, Load Modifying Resource Reforms Draft White Paper Version 1 and all the required data to calculate the capability? In these types of LMRs, the market participant is submitting a MISO-approved statistical sample that represents the LMR, rather than a completely metered aggregation of all loads.

Clarification needed - Maximum Response Time affects DRR Accreditation

In the LMR whitepaper under section 2.1.2 page 12, Table 1 and Figure 1 indicate that the 6-hour response time only affects accreditation, and only for DRR. But MISO doesn't explain how exactly the choice of response time will affect only DRR accreditation, and how it differs from LMR accreditation. Please elaborate.

LMR-BTMG accreditation should be grossed up for PRM%, same as is done for LMR-DR.

Currently, MISO Tariff section 68A.8 Module E-1 page 16 states that BTMG, DEAR, DR and EER should be grossed up by the transmission loss percentage. Section 69A.3.2 pg 58 (for EE), and 69A.3.3 (for DR) states that the resource will also be grossed-up by the applicable PRM in accordance with Section 68.A.2 in addition to the transmission loss percentage. However, Section 69A.3.3 (BTMG) states that the BTMG's will only receive the transmission loss percentage gross up.

This appears to be an inconsistency in the accreditation value of customer-sited assets, and demonstrates unequal treatment of LMR's between LMR-DR and LMR-BTMG's. This would be a good time to reconcile what must have been an oversight in the disparity between grossing up PRM % values for Demand Resources but not for BTMG’s. GRE would like MISO to clarify in future proposals that this design element intends to preserve the existing treatment of LMR-DR’s but also specifically introduces the PRM % add back for LMR-BTMG’s. This requires a tariff revision to section 69A.3.3.

Availability Requirements

Firm Service Level LMRs should have an expectation to provide Accurate Availability  - GRE agrees.

GRE agrees that LMRs with a Firm Service Level should still put forth a good modelling effort to project and forecast available DR for MISO dispatch. This is required for accurate insights into the safety relief valve value that LMRs are meant to provide.

The 10% tolerance band expected for Real Time Availability seems arbitrary; MISO should provide more justification for the error band size, and the overperformance tolerance band lower limit should be larger than the underperformance tolerance band upper limit. 

Some LMRs are both thermally influenced and significantly impacted by human behavior and the interaction of these two variables can be challenging to incorporate into real-time hourly availability models, i.e. Residential AC and Heating.  We have known modelling choices along the way that we typically take a conservative approach, to avoid underperforming during an event.  LMR's are influenced both by weather conditions and customer behavior, and they have tremendous volatility. Market Participants may often deliberately de-rate the registered capability of an LMR as a risk buffer. This is done to avoid underperformance penalties - but now MISO is introducing over-performance penalties. To be penalized if the delivered demand response from a LMR exceeds 10% of its hourly predicted availability could become preventative from MP registering these types of LMRs. 

MISO should consider DRR Type I to have a tighter tolerance band than the LMR tolerance band expectation since one motivation is for a more efficient market - in which DRR participate more regularly. Also, the 10% tolerance seems to be an arbitrary choice for market offer accuracy. Can MISO provide some analysis to demonstrate why this value was chosen? What about some other statistical measures, like something based on the standard deviation of the forecast error?

Also, the underperformance tolerance band should be different than the overperformance tolerance. The severity of the error for an underperformance outcome could lead to a reliability issue for the grid, but the severity of the error for an overperformance outcome is to re-balance and curtail some generator dispatches - there's an RSG mechanism for this error, and the penalty charges related to DDC rates are much lower than the cost of RT LMP. So it seems LMR penalties magnitude should be consistent with that same phenomenon with generators missing their setpoint instructions.

GRE would like to have time and an opportunity to test our DSRI availability models to determine a reasonable band of accuracy around real meter data.

In addition to the above feedback, GRE would like to ask: Is this tolerance band being evaluated for all 8760 hours that LMR meter data is being submitted for, or just for the 65 Capacity Advisory hours used for accreditation?

Measurement and Verficiation

Proposal: Allow LMR-DR Capability measurements to use settlements-quality meter data.

SAC values shouldn’t be computed from forecast-quality estimates or RT telemetry submitted to DSRI, and 14 days is not enough time to accumulate revenue quality data to submit to MISO for LMR capability assessments. Attachment TT capability hours have a 105-day timeline for submitting data, which is sufficient to allow for settlements-quality meter validations. 14 days is an unusually shorter time frame, and doesn't match with the traditional MISO settlements calendar of allowable submission times. Market Participants are expected to keep DSRI data accurate, however, LMR-DR with hourly variability and weather variability is difficult to predict. Accurate forecasting of retail-level meter data is prone to error. Market Participants should have an opportunity to true up these forecasted availability values with actual meter data after the operating day, after settlements processes conclude - similar to MISO settlements calendars allowing revenue-quality metering to be supplementally submitted at S7, S14, S55, S105 days. This is particularly helpful for FSL LMR’s, or highly variable industrial loads.

Locational EP Node data should not be required, and if submitted should be be estimate-quality, not used for performance or operations.

LMR-DR’s should continue to be dispatched and evaluated at the CP Node Level. EP Node data reports can represent estimates of local capability, but MISO should not dispatch and evaluate performance at EP Node resolution. MISO hasn't demonstrated why EP Node aggregation boundaries are necessary for dispatchability or operator awareness. Thousands of residential loads are aggregated at the CP Node level and are registered under statistical modelling frameworks, which are difficult to model and estimate at the EP Node resolution. EP Node locational data requirements are an overly cumbersome new data requirement and is administratively burdensome without benefit to regional reliability.

Miscellaneous

Eliminating Dual Registration is a good simplification. GRE agrees with this plan.

There are too many categories for cross-registration. It’s complicated, hard to explain to colleagues, and MISO makes valid points for the opportunities for gaming with EDR/LMR dual registration option. The venn diagram of 9 different registration options can finally be retired! Thank you.

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 should appear posted under Supplemental Stakeholder Feedback once Stakeholder Relations has an opportunity to do so. 

Voltus comments to RASC on RASC: LMR Reforms (RASC-2019-9) (20240923)

October 25th, 2024

On September 23^rd and October 9^th 2024, MISO presented to the Resource Adequacy Subcommittee and provided additional details regarding their proposals for capacity accreditation and participation for 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 stated challenges and proposed solutions:

MISO’s proposed lack of energy payments for LMR-I and LMR-II deployments creates inefficient market outcomes

Voltus has previously commented (Most recently in September¹) regarding the lack of energy payments for LMR-I and LMR-II deployments. Namely, Voltus has pointed out how forcing industrial facilities or the market participants who represent them to set their cost-representative PRA offer pricing by predicting the frequency of MISO’s MaxGen Alerts, rather than simply compensating them for energy when they are dispatched, guarantees economically inefficient auction results. MISO’s proposal, because of this inefficiency, is in opposition to MISO’s first Market Design Guiding Principle to “Support an economically efficient wholesale market system”. Other wholesale market operators, in their respective emergency demand response programs, provide compensation for energy provided, and recognize the importance of energy payments to creating efficient auction outcomes and continued performance for recurring dispatches.

MISO has proposed a path forward for an accredited resource that is deployed only in emergencies and receives compensation for energy provided in the AME resource. However, the AME resource is not an adequate alternative for many demand response assets who would otherwise participate as an LMR-I or LMR-II. Namely, AME resources, which are deployable only in EEA1 or later conditions, are accredited based on unrepresentative class-averages that de-rate the capacity value of such resources, and MISO’s criteria for accepting AME status are not clear.

MISO should provide examples on the kinds of Demand Resources that would qualify for AME status. In addition, rather than accrediting AME assets based on class-averages (which appear to include generation), MISO should accredit demand response AME resources using the same methodology as other Demand Resources, adding back line losses and PRM.

Proposing no separation between activation of LMRs, particularly for LMR-IIs, creates a resource class with a possibility of impossible-to-achieve performance requirements

MISO has clarified that it does not plan to limit the number of deployments that LMRs may receive within a 24-hour period. When taken in conjunction with MISO’s proposed requirement that LMR-II assets must respond to all LMR deployments or face penalties, this insinuates that, in an extreme weather event like Winter Storm Uri, any asset that registers as an LMR-II could be required to curtail for 2, 3, 4 - 4-hour events in the same day or face severe penalties for underperformance. This concern is particularly prevalent if, as MISO has currently proposed, LMR-IIs do not receive compensation for the energy provided during deployments. 

The proposed performance requirements are uneconomic and virtually impossible for the emergency-only, difficult-to-curtail loads that are most likely to participate as LMR-IIs to achieve. Many end use facilities’ costs of curtailment increase dramatically as the length of curtailment increases. With this in mind, how is a market participant to quantify the potential costs of registering an industrial facility as an LMR-II? They will be forced to be extremely conservative with the offers they make into the Capacity auction and will likely not participate or will be less reliable in subsequent same-day deployments.

MISO should provide a pathway for LMR-IIs to limit same-day curtailments without penalty. It is reasonable for MISO to reduce Capability for such resources in line with their proposals for the calculation of Capability for LMR-I assets that respond to one, but not multiple, events within a given day.

MISO’s current Real-TIme Availability proposals will be unreasonable for many Market Participants

As a part of its proposal, MISO has proposed that assets may face accreditation and financial penalties if their Real-Time Availability does not fall within a “tolerance band” of their actual load. This proposal has two issues: First, MISO’s current aggregation limits make the prediction of load very difficult; Second, MISO’s proposal to penalize the accreditation of resources which indicate an availability that is lower than their actual load is both unnecessary and unreasonable.

It is reasonable for MISO to impose penalties on resources that indicate they have Availability higher than their load actually reflects, and there is precedent for this construct among demand response instruments in other wholesale markets. While Market Participants’ ability to predict individual load behavior is very limited, the prediction of the aggregate value of many individual loads is much more manageable. As a part of instituting its proposal, MISO should remove limits on aggregation - for example, allowing individual Locations with different LSEs to be aggregated together up to the LBA level as long as they are the same resource type (LMR-I, LMR-II) and have the same notification timing. Voltus has previously presented to the DER Task Force² on how this is done in other markets and could be effectively done in MISO. Instituting new aggregation limits would result in MISO operators receiving better Availability data than can be provided otherwise.

In addition, MISO has proposed that a “floor” on Availability is needed because “Offers that are too low present an efficiency concern… MISO deploys too many resources due to offers less than what can be achieved”. However, this construct is unnecessary - MISO’s demand resource accreditation methodology already adequately incentivizes resources to indicate an Availability that is as high as reasonably possible. After all, resources’ future maximum accreditation - and therefore capacity compensation - is based on their Availability. In addition, pending discussions at MISO’s MSC would give MISO’s IMM the ability to investigate economic or physical withholding for resources that appear to be attempting to misuse market power.

As an example, consider an industrial asset that expects it may need to shut down 50% of its curtailable load in the next few hours as orders are completed. It can be difficult or impossible for such resources to perfectly predict when such a task may be complete. To avoid over-representing its capability to MISO, the asset’s Availability is reduced to 50%. However, under MISO’s proposal, the asset would receive accreditation of much lower than 50% (despite having an actual curtailment capability greater than 50%) for each hour until the asset actually shuts down.

In this scenario, without the lower-bound requirement, the asset is already incentivized to more accurately predict its schedule so that it can maintain Availability closer to 100%. However, with MISO’s proposal, this asset would be excessively penalized for its imperfect predictions despite acting in good faith.

The proposed removal of FSL M&V methods divorces Load Obligations from corresponding LMRs’ capabilities

MISO’s proposal to remove the Firm Service Level measurement and verification methodology will result in assets whose capability as an LMR is detached from their calculated Load Obligations. As an example, consider an HVAC load with a 10 MW load obligation based on historical usage that can fully curtail in response to MISO instructions.

If deployed on the first hot day in a stretch of mild days, the asset’s Attachment TT capability as calculated during that deployment might only be 8 or 9 MW – however, the asset can be completely curtailed as a Planning Resource, representing no load at MISO’s system peak. The net effect is that this resource will still have a “phantom” 1-2 MW of load obligation that the LSE is responsible for. MISO needs to provide more details on how such a scenario will determine an asset’s accreditation.

Finally, MISO’s proposals for how resources’ provided FSLs will impact their accreditation (and tolerance bands) are not clear. MISO should provide examples about how their proposals would accredit and set tolerance bands for assets with non-zero FSLs.

MISO’s methodology for calculation of accreditation may not accurately reflect an asset’s actual capacity value

MISO indicated in their white paper that, for the first year of participation, an asset’s accreditation will be equal to “The difference in Maximum Capable Response and Minimum Operating Amount (Firm Service Level)” multiplied by its Load Factor. Many resources, however, will have a load factor that is not representative of their capabilities during MISO emergencies. Consider as an example a big box retail store, whose HVAC-driven load factor will likely be low throughout most of the season but will likely be high during Tier 1 or Tier 2 RA hours.

MISO should instead determine assets’ first-year accreditation by multiplying the difference in Maximum Capable Response and Minimum Operating Amount by the Load Factor during Tier 1 and Tier 2 RA hours.

In addition, once participating, MISO has proposed to base the accreditation of a given resource in a given season on its Capability during the previous 65 RA hours, beginning with a lookback window of one year but extending beyond that as necessary to reach 65 hours. In the Fall and Spring seasons, however, RA hours are rare and MISO may need to extend back many years to collect the necessary amount of data to determine accreditation. This older data may no longer be representative of a resource’s capability. MISO needs to clarify how this very real situation will function.

Finally, MISO must define how exceptions will function in the case of resources whose load or capability, whether due to growth or operational changes, has demonstrably changed from their previous capability.

Assets that can respond for less than 4 hours should have a pathway to accreditation

MISO’s proposals do not include any mechanism whereby assets that can respond for less than 4 hours may be accredited for capacity. However, this excludes potentially valid resources that could be willing to provide resource adequacy to MISO’s system in shorter, one- or two-hour deployments.

MISO should allow for LMR-Is and DRRs to receive accreditation shorter deployment times, receiving a Capability of 0 for hours of deployments that extend beyond their deployment limits. Doing so would incentivize (particularly residential and storage-limited charging) Demand Resources to participate as Planning Resources in MISO’s markets, rather than sitting on the sidelines. 

MISO should allow for EDR deployments at the same stage as LMR deployments, or offer energy payments for LMR deployments. 

MISO has proposed to eliminate the EDR instrument, noting that the instrument today (1) has a very low probability of being deployed due to its deployment in Max Gen Event Step 2b (whereas LMRs are deployed in Step 2a), and (2) has difficult-to-track availability due to submission of offers in the EDR offer tool. MISO has also proposed that the elimination of EDRs may happen ahead of other LMR reforms, as EDRs are not dependent on these reforms.

Today, the EDR instrument represents the only way for a demand response asset to receive energy payments for deployments while also limiting deployments to emergency conditions. Contrary to MISO’s statements at the October 9^th RASC, dual-participation as a DRR-LMR does not provide an adequate alternative to dual-participation as an LMR-EDR – namely, DRR deployments today are in response to market signals rather than emergency conditions. Many demand response participants are willing to curtail to provide support to the MISO system in emergency situations, but cannot curtail purely in response to market signals. Nonetheless, as discussed supra, it is important for these assets to maintain access to compensation for energy provided during deployments to provide economically efficient Capacity Auction offers.

Instead of eliminating the EDR instrument without providing any alternative, MISO should consider (1) offering energy payments for LMR deployments, or (2) adjusting EDR deployments to be alongside LMRs in Max Gen Event Step 2a, and allowing EDRs to submit hourly offers in the DSRI. Either option provides a path for assets to receive energy payments for emergency deployments while addressing MISO’s stated concerns. 

If MISO is to remove the EDR instrument without making such alternatives available, this will result in Planning Resources whose Auction offers must be inefficiently high to cover potential emergency deployment costs; that is, in all likelihood, MISO will experience a loss of valid Planning Resources. As a result, such a change is immediately relevant to LMR reforms, and should not be enacted separately from other proposed reforms.

¹ Volus comments submitted by Nate Cole, https://www.misoenergy.org/engage/stakeholder-feedback/2024/rasc-lmr-reforms-rasc-2019-9-20240821/

² DER Registration Tool & Process Needs in MISO, Presented 2023-04-11 to the MISO DER Task Force https://cdn.misoenergy.org/20230411%20DERTF%20Item%2005%20Device%20Registration%20in%20RTOs628468.pdf

Minnesota Power Appreciates the opportunity to provide feedback regarding proposed LMR reforms.  Minnesota Power continues to be concerned about the current proposal and the more involved details on accreditation and penalties result in a more complicated construct.  We fully expect based on a number of conversations with customers that the participation level will decrease.  These are customers providing proven documented capacity resources that will no longer be providing capacity to the system.  There are numerous challenges of procuring additional capacity and the situation is avoidable if MISO would enact the stakeholder feedback provided.   The following points are worth reiterating for the Minnesota Power position on the LMR reforms:

1. MISO could pursue a verification process to show the cause of the gap from the accredited MW to the available MW.
2. The six hour deployment timeframe needs to be used for an EEA 1 level emergency.
3. The unit commit process needs to be used as a more comprehensive learning process to more clearly understand system attributes required for the system to remain reliable.
4. The Unit commit process should also include performance metrics that properly take into account uncertainties with a well documented process of what is driving the timing for needing emergency resources, rather than creating a narrative of the required response time based on the final high level description of the system needing additional resources.  This will allow a more documented method for establishing the required timeframes for LMR.
5. The unlimited number of events is a contract term that customers are not able to accept.
6. The 30 min response time for an EEA 2 s also a contract term that customers are not accept. 

Minnesota Power is hopeful that a resolution to LMR reform takes the path of meeting the system needs and continuing to be a reliable resource. 

Advanced Energy United appreciates the opportunity to submit these comments in response to the Midcontinent Independent System Operator, Inc.’s (MISO) request for stakeholder feedback on its updates to its Load Modifying Resource (LMR) reforms proposal, following the September 23 and October 9, 2024 meetings of the Resource Adequacy Subcommittee (RASC).

Advanced Energy United is a national association of businesses making the energy we use secure, clean, and affordable. Advanced Energy United is the only industry association in the United States that represents the full range of advanced energy technologies and services, both grid-scale and distributed. Advanced energy includes energy efficiency, demand response, energy storage, wind, solar, hydro, nuclear, electric vehicles, and more. The comments expressed in this submission represent the position of Advanced Energy United but may not represent the views of any particular member. 

MISO is seeking stakeholder feedback on the following: Accreditation of Demand Resources, Non-Intermittent BTMG, Intermittent BTMG, and AME Generation Resources; Availability Requirements; and Measurement and Verification. Advanced Energy United offers the following feedback on these topics:

Accreditation of Demand Resources, Non-Intermittent BTMG, Intermittent BTMG, and Available Maximum Emergency Generation Resources: Although the two LMR Type I and II participation models provide some flexibility in offering different response times at 30 minutes and 6 hours, as well as and deployment periods, they both share one deficiency: they are not able to receive energy payments. This may create inefficient outcomes in the capacity market. Without energy market payments, some facilities may not be willing to curtail if doing so would not cover the costs. Under the current Emergency Demand Response participation option, a project could dual enroll to receive those additional payments. Under the latest proposal, MISO has removed the dual enrollment. Without this, a project would need an unachievably high capacity price in order to clear the auction, most likely leaving many MW on the table. Although the DRR model allows for both energy and capacity payments, it cannot replace the current dual participation option. There should be opportunities for projects to participate based on both energy and economic conditions. Additionally, MISO should create additional flexibility for projects that cannot respond for 4 hours. There should be another option for resources that can only respond for shorter times to participate in the capacity auction, such as those with shorter deployment capabilities from 1-2 hours. We also have concerns over making sure accreditation impacts accurately reflect the greater number of events where LMR Type I resources could be called under Max Gen Alerts compared with the LMR Type II being called at Energy Emergency Alerts 2 events. Type II must respond quicker but less frequently, whereas Type I has more time but will be caller more often. MISO should also reconsider adding a backstop to limit the number of required deployments.

Availability Requirements: MISO’s latest reforms include the creation of tolerance bands that would penalize performance above or below submitted offers. There are different consequences for errors around inaccurate availability offers. Requiring a minimum offer may unfairly penalize assets so penalties should be based off the best performance between a test/event, and average performance over the test/event as a means of determining the ongoing LMR derate. MISO should accredit resources based on their stated availability under the upper bound and there is no need for burdensome lower requirements. To ensure demand response providers can correct for underperformance, MISO should implement only a 1-year carry forward for derating LMR accreditation based on a test/event, as opposed to a derate that’s applied in perpetuity.

Measurement and Verification: MISO should revisit the meter data requirements to allow all resources to participate. Many interval meters don’t collect this granular load data and for small assets <100 kW it isn’t worth it to install revenue grade metering. Requiring 5-minute metering from resources with shutdown times of less than 1 hour would effectively preclude mass market customers from participating as a Type II LMR, and from supporting grid reliability in the MISO footprint via that mechanism. Hourly and 15-minute metering intervals are standard in most utility AMI (Advanced Metering Infrastructure) that's been deployed to date and 5-minute metering would necessitate installing hardware on site which diminishes the economic feasibility of capacity participation by small-scale resources. Like 5-minute metering, requiring small-scale resources to telemeter their availability to MISO in real time would largely preclude those resources from participating in the market due to installation and hardware costs, and the fact that most DERs like thermostats, EV charges, etc. do not come equipped with telemetry. RT telemetry has never been required of LMRs in MISO, nor in the context of Capacity Performance DR in PJM, Special Case Resources in NYISO, or Proxy Demand Resources in CAISO. Demand resources in each of those markets continues to be a reliable instrument for ensuring resource adequacy nonetheless. It is standard in other markets, like PJM, for DR providers to provide estimates for daily availability and we would expect MISO to reflect the industry standard in regards to this requirement. MISO should also ensure that testing is not too costly or excessive by balancing cost with the capability of resources to respond to signals to reduce load. It should ensure tests occur during conditions expected during RA hours such as business hours or account for load profiles that will be different outside of these hours. MISO should clarify if it will allow retesting for underperforming resources and what the intended lead time is for test event notification. Resource providers should have the option to test, regardless of whether or not an event occurs. As for MISO’s claimed assumption that the Firm Service Level (FSL) methodology is no longer valid, we disagree. FSL remains a simple and effective method for determining expected resource adequacy contribution and should remain in place. If the 'counterfactual' peak load hours used for calculating the FSL baseline do not align with the 'critical' hours used for resource accreditation, that is not necessarily a flaw of the FSL baseline.

Given our concerns with the proposed reforms at this time, United suggests MISO delay its filing to continue working through these issues. Advanced Energy United appreciates the opportunity to provide these comments and looks forward to continuing to work with MISO to explore options to further improve LMR reforms in MISO. Please reach out to Lisa Barrett with any questions.

Respectfully submitted,

Lisa Barrett

202.380.1950 x3177

lbarrett@advancedenergyunited.org

WPPI submitted an initial set of comments on this item, which were posted on October 4.  We reiterate those comments and offer some additional comments below on subsequent MISO postings.  In addition, we support the MPPA comments posted October 16.

MISO’s October 9 LMR presentation at RASC

(https://cdn.misoenergy.org/20241009%20RASC%20Item%2008ai%20MISO%20Presentation%20on%20LMR%20Reforms%20(RASC-2019-9)651958.pdf)

1. Slide 2 – MISO says its “proposed accreditation methodology for Demand Resources and Behind the Meter Generation (BTMG) aligns with the accreditation framework for Generation Resources.” 
   1. We note that the critical alignment for LMR DRs is not with generation resources, but with calculation of the load obligation.
   2. Consistency is a reasonable objective, in general, but it is also important to recognize where different resource characteristics justify differences in accreditation methodology.
2. Slide 2 – “MISO’s proposed real-time availability requirements ensure reliable and efficient grid operations during emergency conditions”
   1. MISO has not shown to our satisfaction that their proposal will avoid uneconomic deployment of LMRs with lead times exceeding 30 minutes.
3. Slide 4 – “Real-time availability data indicates far less capacity (~10%/12 GW) than the Planning Resource Auction’s cleared quantity”
   1. As stakeholders have noted many times, we should examine the reasons for this gap and make targeted changes to address the problems revealed in that examination. 
4. Slide 4 – “Current accreditation is only based on LMR’s contribution during seasonal peak, regardless of whether actual reliability needs are during the peak conditions”
   1. We note that this description is not actually consistent with the acceptable accreditation approaches described in Section 4.2.7 of BPM-011.
   2. Also, as in the comment above, concern about a specific element of accreditation would support targeted changes to the accreditation methodology, in alignment with changes in the methodology for determining LSE Load Obligation to similar hours, rather than the much larger modification MISO proposes.
5. Slide 4 – LMRs “Will be relied on more in the future”
   1. This is possible, but not substantiated by MISO, and it runs counter to effect of RBDC, which MISO now expects to lead to summer PRA clearing 3.2% above PRMR, as described at the October RASC meeting.
6. Slide 6 – Currently there is “no incentive to provide accurate availability data”
   1. WPPI strongly disagrees with this framing – providing accurate data is part of our job, which we take seriously, and we expect provision of inaccurate information would eventually lead to unwelcome scrutiny and, perhaps, additional adverse consequences.
7. Slide 8 – “Agree [that there should be consistency between LMRs & Load Obligation] but challenges to how demand is handled in LOLE prevent perfect alignment”
   1. This statement requires explication.  It appears to us that essentially perfect alignment between a load’s contribution to Load Obligation and corresponding LMR DR accreditation is straightforward, and that this is not materially affected by “how demand is handled in LOLE” analysis used to set PRMR.
8. Slide 11 – “MISO requires accurate real-time availability and visibility information which precludes having a FSL M&V methodology”
   1. Provided that accurate RT availability information is supplied to MISO, there is no obvious basis for why FSL M&V methodology is precluded.  See also comment 15.c, below.
9. Slide 15 – “MISO requires unlimited deployments in order to ensure reliable operations”
   1. This statement appears untethered to the analytical framework in which we consider resource adequacy.  In order to meet the reliability level anticipated in the LOLE analysis—which is all we should be focused on—MISO needs resources to perform as assumed in that analysis, complete with any assumed limitations, which includes forced- and planned-outage propensity and could include deployment limits for some LMRs.
   2. MISO has not shown that LMR deployment beyond the current limits would have a material impact on resource adequacy.
10. Slide 16 – “MISO needs to strengthen these [testing] requirements to ensure resources are able to perform consistently with their operating characteristics included in their registration”
    1. Testing can be very costly for some end-use demand interruption, and MISO should explore ways to make demonstration of capability less onerous.
11. Slide 17 – “Better Integration of LMR Data into MISO Operations Enhance Tools • MISO agrees. Having LMRs integrated with other resources will improve operator visibility and decision making”
    1. We would ask MISO to provide information on their efforts at RASC rather than just assuring us that MISO is working on this.
12. Slide 18 – “Near-Term Wind & PV Forecasting • Not within the scope of LMR reforms”
    1. WPPI believes this is well within the scope of the stakeholder-approved problem statement.
13. Slide 32 – “Accurate availability is essential to ensure reliable and efficient grid operations”
    1. We are in favor of providing MISO with the most accurate data available.  However, perfect accuracy may not be achievable for some LMRs and forecasts will be uncertain for a larger set of LMRs.  MISO should accommodate these characteristics.
    2. Once already-discussed improvements to existing reporting tools are implemented, it appears remaining uncertainty around LMR will be a relatively small source of overall uncertainty for MISO operators, and should be treated accordingly.  We welcome a more detailed quantitative discussion from MISO on all the sources of uncertainty in MISO operations.
14. Slide 35 – “5-minute meter data will be required around deployments for resources with less than 1 hour shut down time”
    1. MISO has not justified this requirement, which may serve as a deterrent to reporting notification times less than one hour
15. Slide 37 – “The underlying assumption to this [FSL] methodology is no longer valid….As risky hours shift into non-traditional times, load performance may be quite different [from the period used for accreditation]”
    1. The first statement requires explanation.  We understand the key assumption underlying the Firm Service Level methodology to be consistency between accreditation and the demand level incorporated in the LSE demand forecast.  This underlying assumption is not “no longer valid,” as it is straightforward to implement a framework in which it is achieved.
    2. Risk shift to non-traditional times does undermine the logic of a Firm Service Level approach.
    3. MISO ties the proposed changes to DR accreditation methodology to the need for accurate real-time meter data.  As discussed at the October RASC meeting, this issue does not arise for DR LMRs that choose to provide MISO with real-time DR meter data.  Accordingly, we would ask MISO to retain the existing Firm Service Level framework at least for resources that provide this information.
16. Slide 43 – “MISO is considering allowing for the replacement of ZRCs if underlying contracts are changed”
    1. We would ask MISO explain in more detail what it means by this.

Draft LMR white paper posted with the October RASC meeting materials

(https://cdn.misoenergy.org/LMR%20White%20Paper652580.pdf)

1. Generally, we feel it is important for the white paper to deal with facts, conclusions that logically follow from those facts and design choices, with clear accompanying explanations.  The initial draft appears to rely significantly on unsupported assertions of fact and design-choice explanations that fail to consider the full range of alternatives.
2. “The LMR instrument is an extension of various programs used by vertically integrated monopolies under retail rate regulation that are faced with developing periodic integrated resource plans.” [p. 5/32]

• • We note only that demand-side capacity resources were not historically exclusive to vertically integrated monopolies, to Resource Planners and Owners under retail rate regulation, or to entities obligated to develop integrated resource plans.  Demand-side capacity programs arose in the context of least-cost planning, something that is close to universal across the industry.

3. “LMR-type assets were used by LSEs to meet ‘super-peaking’ needs, or those few hours (< 50 hours per year) when demand was much higher than the expected forecast.” [p. 5/32]
   • We note that critical hours are not driven only by high demand but also high levels of generation outages, and would suggest that MISO consider revising this sentence.

3. “The MISO Region is experiencing growing risks to reliability because of changing resource mix, increasing demand, increase in frequency of extreme weather events, and shrinking Planning Reserve Margin.” [p. 5/32]

• • It is illogical to say that the MISO Region is experiencing growing risks because of “shrinking Planning Reserve Margin” (PRM).  PRM is set each year so as to maintain resource adequacy at a constant level.  It may be that what MISO means to say here is that surplus capacity has been shrinking.  If so, this should be re-written to avoid confusing these distinct concepts.  In principle, changing resource mix can be accounted for in the LOLE analysis that leads to setting PRMR.  While it’s possible that we are failing to properly model the changed resource mix, MISO should explain why they think this is so, rather than invoking this as a risk factor without explanation.  Similarly, in principle we should be able to account for changes in weather patterns in determination of PRM.  Again, MISO should substantiate this factor as a reason why our existing processes for determining PRM are not adequate (giving due consideration to trends such as milder winters we are now experiencing in MISO north than in decades past).

5. “Operating at or near-minimum Operating Margin requirements exposes the MISO region to greater impacts from correlated risks (e.g., extreme weather events and natural gas availability).  These risks are exacerbated by ongoing trends, which have decreased the value of resources that cannot be dispatched quickly, with short notification times, or accessed outside of emergency operations.” [p. 5/32]

• • We would ask MISO to specify the “trends” referred to in the second sentence.  We would also take issue with the framing that identifies the problem strictly as the LMRs themselves without considering whether this points to the need for changes to MISO operations.  An alternative framing, for example, could be that MISO has failed to integrate LMRs into its operating systems to allow them to be considered along other resources in the RAC and LAC processes, which would allow tying emergency declarations to those commitments.  We recognize that both parts contribute to operating challenges, and we believe both should be considered explicitly in the white paper.

6. “Balancing the response time requirements of asset owners to deploy LMRs with the requirements for MISO to use them effectively requires moving some of these resources up the stack to be deployable during MaxGen Alerts.” [p. 6/32]
   • MISO evidently believes it can effectively use Capacity Resources with response times up to 24 hours.  It is not clear to us why MISO could not then effectively use LMRs to the extent these were incorporated into MISO’s forward-looking commitment systems.  Moreover, even if it were appropriate to deploy six-hour resources at Alert, we have not seen a basis to do the same with all resources with notification times exceeding 30 minutes.

6. “These accreditation efforts will bring emergency-only resources’ accreditation in line with Schedule 53A while accounting for the unique operating characteristics, outage scheduling and LOLE modeling.” [p. 6/32]
   • MISO’s focus on alignment with Schedule 53 appears misplaced.  We incorporated both Tier 1 and Tier 2 hours into the Schedule 53 framework because we wanted to reduce outage-driven volatility by expanding the sample size and availability of generators should be expected to remain relatively constant across Tier 1 and Tier 2 hours.  Demand resources, in contrast, are likely to have significantly different capability during Tier 1 and Tier 2 hours.  Failing to recognize these different resource characteristics—as MISO appears to be doing in proposing that both Tier 1 and Tier 2 hours be used for accreditation of LMR DRs—is not a sound approach to determining expected LMR DR capability during the hours when capacity is most needed.  Accordingly, at a minimum, MISO should remove Capacity Advisory Tier 1 hours from the proposed process for accrediting LMR DRs.

6. “Under the current system, there is no penalty or incentive to provide accurate availability information, which has been identified as one cause of the discrepancy between the accredited value of LMRs and the real-time availability volume of LMRs.” [p. 6/32]

• • Again, WPPI would dispute that there is no incentive to provide accurate availability information. Our operators provide accurate availability information because it is their job to do so.  WPPI is focused on providing accurate information as a matter of Good Utility Practice and to avoid the consequences of providing inaccurate information, which could include referral to MISO’s market monitor or regulatory authorities, blame for operational problems and adverse publicity.  We would note, conversely, that there is no apparent incentive to provide inaccurate information today, and we would dispute that the purported lack of incentives has been identified as a cause of the discrepancy.  Moreover, MISO, which is the only party that could shed significant light on the sources of the capacity discrepancy, has failed to provide useful information on this issue over the last six months of discussion, and at the September RASC went so far as to deny that this was a significant motivation for MISO’s pursuit of LMR reform.

9. “The LMR reforms will … improve the alignment of capabilities with payments received and align the accreditation of emergency resources with other resources.” [p. 7/32]
   • We stress that the key alignment for LMR DRs is between LMR accreditation and the corresponding demand used to determine capacity.  DR accreditation will be correct to the extent it is consistent with Load Obligation calculation, even if it does not match generator accreditation.

9. “When this effort is completed, MISO will have transitioned to an accreditation methodology that accredits all resources based on when they are needed the most to meet increasing system risk.” [p. 8/32]
   • As noted above, using Tier 1 Hours to accredit LMR DRs deviates from accrediting based on capability when these resources are most needed.

9. “MISO and stakeholders debated the problem statement related to the accreditation of LMR resources. After several iterations of feedback and refinement, MISO developed the following problem statement” [p. 9/32]
   • We question whether “several iterations of feedback and refinement” is an accurate representation of the single formal feedback item pertaining to the initial MISO problem statement and MISO’s single revised version.  This description also fails to recognize that RASC stakeholders overwhelmingly approved an alternate problem statement in a vote that MISO declined to respect.  While we understand why MISO would want to characterize the history this way, we must emphasize that it does not contribute to the credibility of the white paper as a whole.

9. While developing the LMR reforms, MISO has identified that eliminating dual-registration and EDRs requires aligning the DRR and LMR instruments. Currently, a DRR can be capacity resource, while a LMR is a Planning Resource.”  [p. 12/32]
   • We note that, under MISO’s tariff, Capacity Resources are a subset of Planning Resources.  We suggest revising this section to reflect that fact, e.g., by replacing “is a planning resource” to “cannot.”

9. “A review of the data in Figure 3 shows that an EEA 1 or an EEA 2 event is most often preceded by a less than 30-minute warning (6 escalations to EEA 1 or EEA 2 out of 9 total). This high probability of short notice renders long-lead time LMRs ineffective.” [p. 14/32]
   • MISO has not provided sufficient data to conclude that long-lead time LMRs are ineffective.  What is needed, which WPPI asked for at the October RASC meeting, is the end time as well as the start time of declared events.  In many cases, LMRs may be able to deploy for a full four hours even if they do not start at the beginning of the event.  It appears that, historically, Event Step 2a declaration periods have exceeded four hours roughly half the time, and that the average length of these declaration periods exceeds six hours.
   • Moreover, to the extent MISO can incorporate LMRs into its RAC and LAC processes, there is no obvious basis to deem longer-lead LMRs ineffective than for non-emergency capacity resources with the same lead times.

9. “To be able to use long-lead time (> 30 minutes) LMRs, MISO needs to deploy long-lead LMRs earlier in the emergency procedures. The data here shows that notification times leading up to Max Gen Alerts and/or Warnings provide enough notification time to effectively use these resources to provide consistent reliability benefits.” [p. 14/32]
   • We reiterate that we are open to earlier deployment of longer-lead LMRs (something that is possible under existing rules).  However, we do not agree that, under the current MISO Market Capacity Emergency procedures, Capacity Alert is the appropriate step for deployment of all resources with notification times exceeding thirty minutes.  This appears to us likely to lead to deployment of high-cost LMRs during low-price conditions before MISO has availed itself of its capabilities under Warning, Step 1a and Step 1b, which should lead to steady price increases as the capacity margin becomes tighter.

9. “Intermittent Behind the Meter Generation (Intermittent BTMG): An Intermittent Resource used to serve wholesale or retail load located behind a CPNode that is not included in the Transmission Provider’s Setpoint Instructions and in some cases can also be deliverable to Load located within the Transmission Provider Region using either Network Integration, Point-To-Point Transmission Service or transmission service pursuant to a Grandfathered Agreement.” [p. 17/32]

1. • We note that the existing tariff definitions of “Resource” and “Intermittent Resource” are circular, which does not help here.  We would suggest starting with the definition of BTMG rather than Intermittent Resource in developing the definition of Intermittent BTMG.

16. Type II resources must provide MISO all available MWs they can deploy, regardless of how many deployments have occurred.” [p. 17/32]

2. • It’s fine to say that deployment is required, but this is much less useful if not accompanied by a description of the consequences of failure to deploy.  Just as MISO says earlier in the paragraph that Type I LMRs will have failure to offer incorporated into accreditation, we would suggest that MISO provide at least a brief description of the proposed consequences for a Type II LMR failing to deploy.

17. “MISO does not expect the historic numbers of deployments for LMR – Type II resources to increase but has found that these operational restrictions have hindered the effective usage of these resources.” [p. 17/32]

1. • We don’t believe MISO can substantiate that existing seasonal deployment limits have hindered effective LMR use, given that MISO has not approached these limits.  Accordingly, we recommend removing or revising this statement.

18. “Furthermore, LMR – Type II resources that are a BTMG that fails to perform will be treated as a Demand Resource that has failed to reduce load.” [p. 29/32]

2. • WPPI struggles to make sense of this proposed design element, for which MISO provides no rationale.  Accreditation and penalty regimes need to recognize the differing characteristics of different resources.  All generators have some probability of failure to start.  Accreditation of BTMG should account for this just as accreditation of Capacity-Resource generators does.  Moreover, this proposal may provide a disincentive for BTMG to register as type II LMRs, which would run directly counter to MISO’s stated goals.

Advanced Energy Management Alliance

MISO Resource Adequacy Sub-Committee (RASC)

“LMR Reforms (RASC-2019-9) (20240923)”

October 25, 2024

Advanced Energy Management Alliance (“AEMA”) [1] respectfully submits the following comments to the MISO Resource Adequacy Sub-Committee (“RASC”) on the feedback request made by MISO at the October 9, 2024, meeting of the RASC.[2] AEMA is a trade association under Section 501(c)(6) of the Federal tax code whose members include national distributed energy resource companies and advanced energy management service and technology providers, including demand response (“DR”) providers, as well as some of the nation’s largest demand response and distributed energy resources. AEMA members support the beneficial incorporation of DR and distributed energy resources (“DER” or “DERs”), including advanced energy management solutions, into wholesale markets as a means to achieving electricity cost savings for consumers, contributing to system reliability, and ensuring balanced price formation. These comments represent the collective consensus of AEMA as an organization, although they do not necessarily represent the individual positions of the full diversity of AEMA member companies.

At the October 9^th meeting of the RASC, MISO presented their “final design” proposal for Load Modifying Resource (LMR) accreditation reform. AEMA appreciates the positive changes that MISO has made to its original proposal. AEMA is conceptually supportive of MISO’s proposal to create two participation options for LMRs in the form of either an LMR-Type I or an LMR-Type II. This expansion of options appears to be a reasonable approach to give MISO Operations access to some resources ahead of EEA 2 events, while preserving a participation option for those resources only available in extreme emergencies. 

AEMA is concerned about multiple elements of this complex proposal by MISO. The general concerns include the following:

• Unlimited Response Requirement: MISO has proposed an unlimited number of responses from all types of LMRs. As previously stated by AEMA and many other stakeholders, this aspect is problematic because it makes the quantification of risk nearly impossible when working to understand participation obligations for LMRs. Without any backstop on the number of responses required and no energy payment for deployment response, a resource could be called dozens of times without any mechanism to balance the impact on the customer. This uncertainty is of particular concern to some large industrial consumers who are significantly impacted by interruptions. Many of these resources have supported grid reliability for decades and can continue to do so on a limited basis but without some balance to the potential impacts, they may be forced to stop participating in supporting grid reliability. 
• Lack of Energy Compensation for LMRs: MISO has proposed that there will be no Energy payments for deployment of LMRs. As mentioned above, AEMA encourages MISO to consider the addition of an Energy payment during deployments (in much the same way that traditional generation resources receive an Energy payment in the same situation) to offset the participation uncertainty and other design changes proposed by MISO. 

While some stakeholders have suggested that LMRs should push this risk factor into their capacity offer in an attempt to capture the deployment risks in their capacity revenues, this suggestion creates concerning inefficiencies in the capacity market pricing. The most efficient market results occur when resources can offer and clear in the markets at offers that reflect their actual costs as much as possible. Adding an offset to the capacity offer for “potential interruptions” would not reflect actual costs of offering capacity independent of the variable event impacts. Adding an energy payment would separate the two impacts and more closely reflect traditional generation that separately receives capacity revenue and energy revenue independently when cleared in the different markets.  

• Elimination of Emergency Demand Response (EDR): MISO has proposed to eliminate the opportunity for resources to register as an EDR. AEMA does not support this change. EDRs provide a customer with an option to respond during an emergency and receive compensation for the response. AEMA believes that with the lack of any energy compensation for an LMR, the EDR mechanism should remain available as a participation option. With MISO’s change to an unlimited number of responses, the option to receive an Energy payment in the event of an activation allows customers some mechanism to recover costs of the impact of deployment and balance the uncertainty with the actual number of responses and the ensuing financial impact. 

While MISO has noted that a DRR receives an Energy payment, registration as a market resource may not be a viable option for some customers because the customers are only permitted (by either the state or federal agencies) to respond to “emergency conditions.” Additionally, the registration and participation requirements for a DRR are much more significant than for an LMR. Again, MISO is proposing a solution that sounds reasonable but may not be legal for some market participants today or may have inordinate costs associated with Day-Ahead and Real-Time market participation.  

• Treatment of Firm Service Level (FSL) Customers: AEMA believes that customers that can curtail to a firm service level provide valuable reliability services to MISO and should be accredited appropriately. During the October 9^th meeting of the RASC, there was significant discussion of FSL customers and confusion over what MISO is proposing. MISO’s comments focused on “load obligation determination” and the presentation from MISO stated that FSL is not “straightforward.” Multiple stakeholders challenged the MISO statements, particularly on the “straightforward” aspect. Despite these disagreements, MISO has indicated in the “Measurement and Verification” portion of the MISO presentation that an FSL customer could get appropriate accreditation. Unfortunately, there was not time in the RASC to discuss this topic in sufficient detail to gain a clear understanding of MISO’s intent. 

AEMA requests that MISO develop examples of the FSL accreditation process and addresses whether MISO will treat a resource that is already at reduced load as a self-scheduled resource for accreditation purposes. If MISO plans to accredit an FSL for their self-curtailed load, then AEMA would support this treatment, but MISO should explicitly address the issue to provide clarification.  

• Elimination of 24-Hour Separation Rule: MISO has stated that it will not be utilizing any separation time between activations of LMRs. Taken to the extreme, this could mean that an LMR is required to respond many times within a single day or even sequentially. This is another concerning aspect of the MISO proposal because it eliminates any certainty on how to evaluate risk of activation for consumers. As mentioned above, this would be another rationale for the inclusion of an Energy payment to balance the uncertainty and inability to regulate how a resource is utilized.
  
  
• Testing Criteria:  AEMA supports the MISO proposal to allow a deployment to count as a test and the provision for opt-out of testing for an LMR-Type II. MISO has also stated that an LMR-Type I will only be tested if requested by MISO and if no deployments have occurred in the year. In the details of MISO’s presentation, MISO states that the tests will be “MISO initiated.” AEMA requests more details on the testing procedure and clarity on whether MISO will be utilizing the “available” capacity in the DSRI for the test expectation and evaluation. MISO should address how a resource that is at “not peak” operations, as reflected in the DSRI, will be treated and accredited during a test.
  
  
• Four Hour Minimum Response: MISO has stated that a resource must be capable of responding for a minimum of 4 hours to receive capacity accreditation. MISO should examine options for response of shorter periods, with a potential reduction in accreditation. 
  
  
• Tolerance Bands: MISO has proposed establishing a tolerance band in the real-time deployment capabilities of LMRs. This bandwidth tolerance is logistically concerning for AEMA, because it creates a potentially onerous requirement for customers like large industrial loads. While the upper bound is not unreasonable, the lower bound is unnecessarily arduous. Consider a large load that is restoring operation to a facility or even a specific production line. This start-up process is often difficult to predict, and MISO’s proposal would penalize a resource for the inability to predict to within a very tight margin. Given that DRs are subject to withholding examination by the IMM, the lower limit is not necessary. AEMA urges MISO to remove the lower bound concept and accredit these resources based upon the stated availability as long as it is below the upper bound.

AEMA appreciates MISO’s consideration of these comments as part of the examination of resource accreditation issues within MISO. We welcome any questions, and encourage you to contact either Katherine Hamilton, Executive Director of AEMA, or DeWayne Todd, representative of AEMA, should you wish to discuss this with AEMA members.

Respectfully Submitted, 

Katherine Hamilton
Executive Director, Advanced Energy Management Alliance
Katherine@aem-alliance.org
202-524-8832

or

DeWayne Todd
DDT LLC
dewaynetodd1297@gmail.com
812-573-8052

The Arkansas Public Service Commission submits that while MISO’s LMR modifications may be reasonable in part, the necessity to provide LMRs for a unlimited number of times in a season, and even an unlimited number of times in a single 24-hour period, may prove difficult for some current LMR customers who rely on the consistency and limitations of MISO’s present LMR construct.  While the Arkansas Public Service Commission understands that MISO’s position is that LMRs can simply accept a lower accreditation for not being dispatched during any capacity advisory hour, the Arkansas Public Service Commission would suggest to MISO that it should introduce some degree of certainty for LMR customers regarding their obligations to dispatch.  Since electing to not be dispatched lowers accreditation, MISO’s proposal may lead to volatility in the LMR value prospect for customers which may discourage them from participating as an LMR.  The Arkansas Public Service Commission suggests that MISO should endeavor to maintain as many LMR resources as it can.

The Environmental Sector appreciates the opportunity to provide comments on MISO’s updates to the LMR Reforms proposal. First, we value the changes and improvements to the proposal that MISO has made through the stakeholder process. Retaining the long lead time LMR product is important flexibility for existing LMR resources who cannot meet a 30 minute response time. At the same time, we support the creation of the new category of short-timed resources. We hope that MISO will continue to work on leveraging the capacity contribution of demand response resources as much as possible. 

The Environmental Sector recognizes that these proposed changes may result in less accredited capacity in the short-term, yet understands that it is increasingly important for MISO operators to have visibility and confidence in registered LMRs. Demand flexibility can help mitigate times of risky periods on the grid. MISO operators need to be able to reliably call upon those compensated resources, and we think the LMR proposal firms up their confidence in this resource.

The OMS Resources and DER Work Groups (OMS Work Groups) appreciate this opportunity to provide feedback on the various design elements contained in the Load Modifying Resource (LMR) reform proposal that MISO presented at the Sept. 23, 2024 and Oct. 9, 2024 RASC meetings. This feedback is from multiple OMS work groups and does not represent a position of the OMS Board of Directors.

The OMS Work Groups appreciate this opportunity to offer a fifth round of feedback to MISO on its proposed reforms to LMRs and other related demand-side resources. While we understand the need for increased certainty regarding LMR availability and a need for more accurate accreditation based on performance during times of system need, we remained concerned that the breadth and complexity of these reforms will lead to a significant decrease in LMR participation and overall cleared capacity.  

Below we express positions on several design elements of MISO’s reform package. We also provide several requests for clarification or more information to improve our understanding of the potential practical effects of these proposed reforms and to safeguard against unreasonable and avoidable LMR attrition.

Accreditation of Demand Resources, Non-Intermittent BTMG, Intermittent BTMG, and AME Generation Resources 

In determining the accreditation for LMRs, the OMS Work Groups believe that MISO should use a three-year look back rather than the proposed one-year look back. The three-year look back is consistent with what has been proposed in the LMR White Paper for BTMG and AME resources, and this would help reduce the year-to-year volatility in the accreditation of demand resources. If a multi-year look back is not appropriate for demand resources, the OMS Work Groups request that MISO provide justification as to why.  

The OMS Work Groups believe that longer-lead time LMRs should not be automatically assigned zero accreditation if they were called within a shorter-lead time than they are physically capable of responding. Instead, they should be eligible for partial accreditation. MISO provided examples during its LMR Reform presentation given at the September 23, 2024 RASC meeting. On Slide 18, MISO shows an example where a resource with a 4-hour shut down time is given a 4-hour notification that it will need to deploy. During the notification window and the deployment, the capability is calculated using the proposed Attachment TT methodology. On Slide 23, MISO shows an example where a resource with a 4-hour shut down time is only given a 2-hour notification that it will need to deploy. During the notification window and during the event hours prior to the resource being deployed, this resource is given zero accreditation (with Attachment TT being used during the eventual deployment). If the resource is responding to the notification and actively winding down operations, they should receive credit for their reduction, even if they are not capable of fully reaching their designated setpoint (some form of partial accreditation for those hours). We suggest MISO reconsider this strategy, and at a minimum, the treatment and accreditation of these resources during the notification window (the time of notification to the time of the event/deployment) should be consistent.

Availability Requirements 

The OMS Work Groups support moving LMR Type I deployment from MaxGen Alert to the  MaxGen Warning stage. Deploying LMR Type 1 at the MaxGen Alert stage would precede curtailing non-firm exports, scheduling external resources, and implementing emergency ratings on transmission lines. This interaction with other emergency actions should not be ignored and needs to be taken into consideration when deciding where to place deployment of LMRs, an emergency resource. A Warning Stage deployment is more consistent with an emergency resource because that is the situation when MISO is projecting less than 0 economic reserves. From MISO’s own Emergency Operating Procedures, “A positive but low Reserve Margin is forecasted in a Max Gen Alert. For a negative Reserve Margin, a Warning or Event should be declared,” and “A negative Reserve Margin means that Load and Operating Reserve Requirement cannot be met with normal Economic Resources.” As the data on the last slide of the September presentation shows, there seems to be ample time to deploy longer lead resources at this stage.

The OMS Work Groups emphasize that this LMR reform package interacts with numerous initiatives and improvements needed across MISO. Thus, a holistic look is needed to ensure these interactions produce the intended effects and a balanced solution is kept in mind. To that end, MISO should clarify how Emergency Operating Procedures will be updated to align with the LMR reforms, including whether MISO will take steps such as curtailing non-firm exports before deploying LMRs.

Measurement and Verification

The OMG Work Groups share the concerns expressed by the LSEs about the complexity of the proposal and would like to draw attention to the data needs and the resources needed to process such data. MISO has proposed to collect hourly meter data for all resources participating as a DRR, LMR, or Intermittent BTMG. In addition, MISO will require 5-minute data for resources with less than 1 hour shut-down time. This meter data will also need to be submitted every 14 days for MISO to review and verify. These proposed requirements raise several questions.

• Does MISO have the resources to truly track and use all of this data?
• Why is 5-minute data needed for all resources under 1 hour shut down time?
• How often does MISO expect to utilize this data for the uses above? Every 14 days? Daily? Hourly?
• Is this ‘command and control’ approach to capability and availability over-solving the problem?
• Is there a way to simplify the proposal to ease the data burden, both on Market Participants and MISO?

Per the LMR Whitepaper, MISO will use this data for a number of tasks, including: calculating capability of LMRs, verifying performance within the specified notification times, auditing resources, verifying appropriate load values, and verifying availability offers. Given the important role of this information in the overall construct, the OMS Work Groups requests a clear definition of ‘meter data,’ when it is needed, and how it will be used.

The OMS Work Groups strongly support standardizing the registration process, finding ways to make it more granular, incorporating automation where appropriate, and exploring better ways to share information among all entities involved in registration. We understand MISO is moving forward with a Locational Enrollment Tool to address many of these issues. We request that MISO provide an update on this effort, its proposed benefits, and its areas of interface with MISO’s proposed reform package.

LOLE Alignment with PRMR

During the discussions around the Direct Loss of Load methodology to accredit non-emergency resources, MISO agreed to defer the discussing potential changes to the PRMR allocation and how LSE obligations might need to reflect usage during high-risk hours. While the OMS Work Groups understood the decision to defer that discussion the PRMR allocation could have a notable impact on the accreditation given to LMRs relative to the assigned load obligation. Using an example of an LMR that is set to lower its consumption to its firm service level when deployed, if the load’s obligation is set at the consumption during the system-wide peak, but the accreditation for the associated LMR is set based on the resource capability during,  risky hours that are no longer aligned with the system-wide peak,  this could create an additional resource adequacy obligation on the load, even if the associated LMR performs perfectly and is behaving exactly as MISO has requested.

During its LMR Reforms presentation at the October RASC, MISO responded to several items from a previous stakeholder presentation. One of the responses was on the topic of alignment with the PRMR determination, and MISO stated that “MISO agrees that LSE obligation should be based on load during the times of highest need and should also align with resource accreditation.” While a significant delay in filing the LMR reforms appears unlikely, the OMS Work Groups request that, at a minimum, MISO provides a general framework on how they propose to align the PRMR allocation with the accreditation proposal prior to filing the LMR reforms at FERC.

Penalties and Incentives

Regarding penalizing LMRs for offering over the tolerance band, is it possible that an LMR may be offering MWs over this band because it is willing to violate its firm service level? In that case, a penalty would not appear to be appropriate as the offer would be accurate. To help stakeholders better understand this interaction, we request more examples of how the proposed accreditation method works with various firm-service levels.

The penalty of disqualifying LMR Type 1 in future PRAs for a missed response to a deployment request may be too severe.

Requests for Clarification and More Information

Several LSEs continue to voice concern regarding MISO’s proposal for unlimited deployments and eliminating the 24-hour separation rule. Although participants can enter 0 MW for Type 1 LMRs, 0 MW entries could result in LMR accreditation that is diluted and may render those LMRs financially infeasible. To understand the potential implications of this decision, we offer the following questions:

• Can MISO provide estimates of how LMR accreditation across a season would change under MISO’s reforms with and without a 0 MW entry for deployment?
• Can MISO allow LSEs to have choices about which LMRs deploy within an LBA (i.e., an LSE is able to optimize its portfolio and respect customer deployment limits)?
• We know what percent of capacity is attributed to LMRs, but we do not understand what resources use AME. Please provide the historic use of AME resources that this accreditation methodology would apply to.
• More information about Attachment TT would help demonstrate that this method produces accurate baselines across seasons and for different types of LMRs.

OMS Work Group members have asked for more information about LMRs relation to the LOLE model multiple times. More insight into LMRs and the LOLE model is required to understand MISO’s choice to accredit LMRs outside of the model.

• What changes to the LOLE model, if any, would be needed if MISO’s proposal to deploy LMRs at an earlier stage is approved?
• Can MISO provide more information about assumptions regarding when and to what degree LMRs are deployed in the LOLE model currently? 
• Would there be other changes, such as how MISO counts the overall quantity of LMR MWs (e.g. the accredited capability)?
• Has Astrapé been consulted regarding the feasibility of these changes?

Conclusion

Overall, the OMS Work Groups appreciate many of the steps MISO is taking. However, there still appears to be fundamental differences between MISO’s proposal and the proposal advanced by a dozen or more LSEs. The LSEs and end-use customers have voiced concerns about the complexity of this proposal. LSEs must explain these reforms to their customers that participate in demand response programs as LMRs. MISO should explore any opportunity to simplify some elements of the proposal. If not, LSEs may need more resources to make accurate accreditation estimates so that they can understand the impacts of the proposals (and to make decisions about managing their demand response programs).

We suggest MISO work collaboratively with LSEs to ensure their concerns are addressed so that the footprint will not unnecessarily lose LMRs. LMRs are a critical tool for states to cost-effectively meet RA requirements and are particularly important at a moment with historic interconnection queue backlogs.