RASC: LMR Reforms (RASC-2019-9) (20241106)

Michigan Public Power Agency (MPPA) appreciates MISO’s work with Stakeholders on Load Modifying Resource (LMR) Reforms through the Resource Adequacy Subcommittee (RASC).  MISO commendably adapted participation models and other aspects of their proposal based on Stakeholder feedback.

Unfortunately, the final design details of MISO’s proposed accreditation methodologies were not available until 11/6 when it published its Load Modifying Resource Reforms Draft White Paper (Version 2), and several aspects of that accreditation mistreat dispatchable Behind the Meter Generation (BTMG) or are otherwise counterproductive.

1. The one (1) year lookback period for accreditation of Non-Intermittent BTMG may distort a resource’s accreditation by understating its contribution to reliability if, for instance, it experiences one significant forced outage.  MISO inadvertently acknowledged as much in its presentation, “20241106 RASC Item 08ai LMR Reforms (RASC-2019-9).pdf”, where Slide 23 listed a 3 year lookback period (while slide 16 used 1 year).  Since BTMG are accredited only during Capacity At Risk Hours and Tier 2 Resource Adequacy Hours, as few as 65 hours per season will be used (note from PY’19’20 – PY’22’23 in MISO N/C there have been 2 instances of > 65 hours in Fall and 2 instances in Summer).  Thus, if a dispatchable thermal BTMG experiences one forced outage that extends over most or all of the 65 hours used for accreditation in a given season, it will forfeit most/all of its accreditation for that season in the next PY (as well as face penalties, addressed below). A dispatchable thermal resource is the same whether registered at MISO as a Generation Resources or a BTMG: a machine that can break down despite excellent maintenance and care.  The 1 year lookback discriminates against dispatchable BTMG when Schedule 53A Resources have a 3 year lookback.
2. LMRs must be accessible 24/7 as availability is uploaded for every hour of the year. Since the day and time of the reliability event is not known beforehand, this is an empirical fact that MISO seems to miss when representing that LMRs only need to be available in an emergency.
3.  MISO does not plan to give outage exemptions to BTMG. Yet MISO expects BTMG to forecast the Capacity At Risk Hours and Tier 2 hours to be able to plan outages or face accreditation issues. This is exacerbated when only doing a 1 year lookback for accreditation.
4. Continuing with the example in 1 above, if a dispatchable thermal BTMG experiences one forced outage that extends over most/all of the 65 hours used for accreditation in a given season, MISO will set the accredited value of this resource to zero for the Season and MISO may disqualify the resource for the remainder of the Planning Year (PY).  When combined with 1 above, this draconian penalty could wipe out a dispatchable BTMG’s accreditation for an entire season for 2 PYs, and the balance of the current PY, all because of 1 forced outage.
5. As a separate example, a dispatchable BTMG that was derated and hence partially responded to deployment during an Emergency ( ≥ 50% Capacity Availability and < Tolerance Band per proposed Tariff 69A.3.9) would be subject to Deficient Energy outside Tolerance Band if registered as a DRR or replacement energy costs if registered as an LMR.  That dispatchable BTMG would also be subject to a penalty in the amount of the ratio of the demand reduction not achieved times the enrolled capacity rating times the Auction Clearing Price (ACP) for each Season for the remainder of the Planning Year, or until such resource fully performs in response to a subsequent Scheduling Instruction or test.  All those penalties would be in addition to the reduced accreditation in that season in the next PY.
6. Penalties for Capacity Availability above the upper bound of the Tolerance Band make no sense during system conditions at or above Capacity Advisory, as other dispatchable resources can be directed to reduce output, thereby creating additional Operating Reserves.
7. How is “Firm Service Level: The amount of customer Load, in MW, that is intended to always be consumed by an end use customer” determined? (Tariff Module A)

Just as dispatchable resources are retiring, removing necessary system attributes while being largely replaced by intermittent resources with fewer or none of those attributes, MISO’s LMR proposal threatens the accreditation of dispatchable BTMG resources.  As it currently stands, MISO’s LMR proposal will reduce reliability and raise costs by pushing legitimate LMR capacity into retirement/non-participation, thereby forcing MPs to replace this capacity at a time when planning reserves are declining and building new capacity resources is difficult as well as costly.

WEC Energy Group developed the following questions and comments in response to Version 2 of the LMR whitepaper.  These comments are not all-encompassing due to the complexity of the whitepaper, the short time for review, and the need to educate and collect input from multiple SMEs within different departments.

1. General comment – Demand Response LMRs that curtail consumption in response to high LMPs should be considered “self-deployed” and accounted for as such.  Operator education and rules for reporting “self-deployed” DR are needed (for example, self-deployed based on economics, self-deployed in anticipation of MaxGen, self-deployed in response to Capacity Advisory, etc.).  DR load that is not consuming by virtue of its normal load factor and production cycles is not “self-deployed”.  DR LMRs should not receive negative accreditation signals when they are simultaneously responding to LMP price signals.
2. Page 9 – We support the deployment of LMR – Type I resources based on lead time, with long-lead time resources deployed before those with shorter-lead times.  We encourage MISO to include this in the tariff, BPMs, and any enhancements to the MaxGen procedure that are forthcoming.
   
   
3. Page 10, Page 15 – Capacity At Risk Hours includes Capacity Advisory Hours but Capacity Advisory Hours do not explicitly exclude MaxGen hours.  Clarification is needed.
   
   
4. Page 18, Figure 5 - The 8.6 MW value in the last row of column Hour 16 doesn’t align with the whitepaper which states that an offer of 0 MW while operating above its FSL of 10 MW will receive 0 MW of accreditation.
   
   
5. Page 18 and elsewhere – The whitepaper refers to LMRs “within the same LBA”.  This language is unnecessary given the forthcoming Locational Enrollment Tool.  One of the reasons for the Locational Enrollment Tool is to allow MISO to deploy LMRs on a granularity smaller than the LBA.  Either an LMR is given a deployment instruction or not, even if its offer is 0 MW.
   
   
6. Page 18, Figure 6 - In Hours 12, 13, and 14, why does the resource receive 0 MW accreditation when it is below its FSL?  The accreditation of a DR LMR below its FSL should not be penalized simply because it is below its FSL even if a MaxGen event is not declared.
   
   
7. Page 19 - We do not understand why an LMR Type I that offers 0 MW and is below its FSL will receive 0 MW accreditation if it is then made available during other hours of the same Capacity Advisory event.  How is this comparable to a solar resource which will not have its accreditation negatively affected during Tier 2 Hours that occur during darkness?
   
   
8. Page 27 – It is understandable that a resource that offers above its Tolerance Band should not receive accreditation at that level.  However, the resource’s accreditation should not be penalized for over-offering.  In the example provided, the resource that offers 8 MW above its Tolerance Band should receive an accreditation of 100 MW rather than 92 MW.  It makes no sense to penalize a resource for over-offering.  Alternatively, MISO can easily implement code to not allow an over-offer based on actual operating conditions of the LMR.  In this case, the LMR at 120 MW with a 20 MW FSL will have a hard-wired offer limit of 100 MW.

Duke Energy provides the following additional comments and feedback in response to MISO’s RASC: LMR Reforms (RASC-2019-9) presentation that was updated 11/6/2024.

Duke appreciates the opportunity to provide feedback.

1. Proposed Accreditation methodologies

Duke Energy supports MISO’s efforts to improve and standardize registration and accreditation as part of the ongoing LMR Reform effort (LMR Reforms Slides 16 – 27).

1. 1. Duke Energy suggests that DRR’s and LMR’s should have a three-year lookback period along with AME Resources and Intermittent BTMG to reduce year-over-year volatility associated with transient weather and system load conditions impacting RA and Tier 2 hours. Several of Duke Energy’s demand response programs, such as residential air conditioner cycling programs, have capabilities which are strongly correlated with system peak conditions typically accompanied by high temperatures.  If the hours and conditions used to accredit LMR capability are highly variable each year, such offerings may be difficult to maintain at the retail level and prohibit participation by Duke Energy’s retail customers.
   2. Duke Energy strongly recommends that MISO develops an API configuration where Duke can report in real-time to the DSRI the actual amount of load available to be curtailed at any given time, like the DR Hub and Data Miner tools available to PJM participants. Duke Energy contends that this improvement would negate the need for many of the proposed accreditation reforms due to capacity values and load levels being readily available and independently verifiable by MISO. Duke Energy also notes that the timeline MISO has set out for this reform, Delivery Year 2028/29, provides enough lead time that MISO should be able to develop an API configuration to the DSRI tool.

2. Proposed Participation Models

 Duke Energy agrees with MISO that the current participation design is complicated and difficult to track (LMR Reform White Paper 652580, page 13).

1. 1. Duke disagrees with MISO’s participation models and proposed deployment order (LMR White Paper 652580, page 9) that would have LMR Type-1’s called on more frequently and earlier than LMR Type-2. 
   2. Duke contends that LMR type-2 should be called before LMR Type-1.
   3. Duke’s LMR Type-1 customers would be those unable to respond within a 30-minute window.  For Duke Energy, they would be made up of large C&I customers where frequent demand response events can cause significant disruption to the customer’s operations and significantly decrease their interest in participating in Duke’s DR programs. These customers are essential to the vitality of DR programs and Duke’s planning resource capacity. LMR Type-2 customers that are capable of 30-minute response would include more automated customer programs, like direct load control of air conditioners. More frequent DR participation for LMR Type-2’s, residential and small business customers, would result in faster response times to MISO and less disruption to the customer. In consultation with Duke’s end-use customers, account managers, and other stakeholders, Duke forecasts approximately 70% of our current MW capacity is at-risk to be reduced or removed due to MISO’s currently proposed LMR reforms. These are MW that are valuable and available to the system today that would need to be replaced with supply-side generation options by Delivery Year 2028/29, which may not be feasible in that time frame.
   4. If MISO does not change the proposed deployment order, Duke contends that limits on the number of times that LMR Type-1 will be obligated to respond to events and/or alerts each year need to be specified. Our large C&I customers have provided feedback that unlimited event obligations are the primary driver for reducing their DR participation under the proposed model. Duke Energy proposes a maximum of 5 event calls per season for LMR Type-1 as an alternative.

3. Proposed Testing and Penalties

Duke Energy supports MISO’s proposed testing criteria for LMR Type 2 for all LMRs and finds the proposed penalties provisions reasonable (MISO LMR Reform White Paper v2, P.28) provided that a resources availability can be reported to the DSRI via an API.

1. 1. Duke Energy disagrees with MISO’s statement that “there is no penalty or incentive to provide accurate availability information” (LMR Reform White Paper v2, Page 2). Duke Energy contends that the lack of automation for reporting availability via the DSRI is the main cause of inaccurate availability information. Duke Energy manually updates its hourly capability daily via the DSRI, a laborious and cumbersome task that can easily be configured by an API capability.

MidAmerican Energy appreciates the opportunity to provide feedback on LMR Reforms (RASC-2019-9) (20241106).

In general, MidAmerican understands the reforms that MISO is recommending but still has some questions and comments:

• MISO continues to ignore MidAmerican’s request for MISO to respond why an LMR Type II can’t have a 120-minute notification requirement like PJM’s current process. MISO should strive to maintain LMRs instead of creating a ruleset that encourages participants to drop out of demand response programs. Please respond.
• Based on the current whitepaper on page 8 and 9, it indicates that DRR resources that clear the PRA still have a day ahead must offer obligation and yet must have a notification and start time less than 6 hours.  Given a normal generator has a day ahead must offer and can have a notification plus start time of up to 24 hours, this is discriminatory.
• Based on the current whitepaper on page 27, 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. A factory may have guaranteed that it will drop to a firm service level, but if the factory decides to just shut down entirely for the remainder of the shift, why should a penalty occur? How can MISO even tell the difference between responding to an event and reducing load for other reasons. MidAmerican understands the importance of having accurate data in the DSRI but penalizing a market participant that over-responds is unreasonable.
• MISO needs to explain how actual curtailment requests will take place once these reforms are in place. Currently, MISO indicates how many MWs are required, and the MP decides how to achieve the reduction. Now that MISO will have locations for these LMRs, does that flexibility go away?
• Related to this reform, 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.
• Regarding MISO Initiated Tests, presentation slide 34 indicates testing may be required when enrolled capacity changes across Planning Years or Seasons.  MidAmerican’s enrolled capacity can change from year to year and season to season based upon customer participation in the current LMR groups.  Can MISO clarify when testing will be required? Please specify if this will be required if there is any level of change or if there were a certain percentage of change that would trigger it.
• Please clarify the look back period for non-intermittent BTMG. It is not reasonable to have a one year look back period. It should be three years.
• It is discriminatory to not allow outage exemptions to non-intermittent BTMG.

AMP supports MPPA's feedback on the LMR reforms issue.

Unfortunately, the final design details of MISO’s proposed accreditation methodologies were not available until 11/6 when it published its Load Modifying Resource Reforms Draft White Paper (Version 2), and several aspects of that accreditation mistreat dispatchable Behind the Meter Generation (BTMG) or are otherwise counterproductive.

1. The one (1) year lookback period for accreditation of Non-Intermittent BTMG may distort a resource’s accreditation by understating its contribution to reliability if, for instance, it experiences one significant forced outage.  MISO inadvertently acknowledged as much in its presentation, “20241106 RASC Item 08ai LMR Reforms (RASC-2019-9).pdf”, where Slide 23 listed a 3 year lookback period (while slide 16 used 1 year).  Since BTMG are accredited only during Capacity At Risk Hours and Tier 2 Resource Adequacy Hours, as few as 65 hours per season will be used (note from PY’19’20 – PY’22’23 in MISO N/C there have been 2 instances of > 65 hours in Fall and 2 instances in Summer).  Thus, if a dispatchable thermal BTMG experiences one forced outage that extends over most or all of the 65 hours used for accreditation in a given season, it will forfeit most/all of its accreditation for that season in the next PY (as well as face penalties, addressed below). A dispatchable thermal resource is the same whether registered at MISO as a Generation Resources or a BTMG: a machine that can break down despite excellent maintenance and care.  The 1 year lookback discriminates against dispatchable BTMG when Schedule 53A Resources have a 3 year lookback.
2. LMRs must be accessible 24/7 as availability is uploaded for every hour of the year. Since the day and time of the reliability event is not known beforehand, this is an empirical fact that MISO seems to miss when representing that LMRs only need to be available in an emergency.
3.  MISO does not plan to give outage exemptions to BTMG. Yet MISO expects BTMG to forecast the Capacity At Risk Hours and Tier 2 hours to be able to plan outages or face accreditation issues. This is exacerbated when only doing a 1 year lookback for accreditation.
4. Continuing with the example in 1 above, if a dispatchable thermal BTMG experiences one forced outage that extends over most/all of the 65 hours used for accreditation in a given season, MISO will set the accredited value of this resource to zero for the Season and MISO may disqualify the resource for the remainder of the Planning Year (PY).  When combined with 1 above, this draconian penalty could wipe out a dispatchable BTMG’s accreditation for an entire season for 2 PYs, and the balance of the current PY, all because of 1 forced outage.
5. As a separate example, a dispatchable BTMG that was derated and hence partially responded to deployment during an Emergency ( ≥ 50% Capacity Availability and < Tolerance Band per proposed Tariff 69A.3.9) would be subject to Deficient Energy outside Tolerance Band if registered as a DRR or replacement energy costs if registered as an LMR.  That dispatchable BTMG would also be subject to a penalty in the amount of the ratio of the demand reduction not achieved times the enrolled capacity rating times the Auction Clearing Price (ACP) for each Season for the remainder of the Planning Year, or until such resource fully performs in response to a subsequent Scheduling Instruction or test.  All those penalties would be in addition to the reduced accreditation in that season in the next PY.
6. Penalties for Capacity Availability above the upper bound of the Tolerance Band make no sense during system conditions at or above Capacity Advisory, as other dispatchable resources can be directed to reduce output, thereby creating additional Operating Reserves.
7. How is “Firm Service Level: The amount of customer Load, in MW, that is intended to always be consumed by an end use customer” determined? (Tariff Module A)

Additionally, MISO's proposal calls for BTMG ISAC to be measured based on the availability when not dispatched and the metered output when dispatched.  The capability (ISAC) should be a combination of the availability and metered output because a BTMG resource could be operating and less than its full output and be available for MISO to dispatch it to full output.

Michigan Public Power Agency (MPPA), supported by Lansing Board of Water and Light & The City of Ames, appreciates MISO’s work with Stakeholders on Load Modifying Resource (LMR) Reforms through the Resource Adequacy Subcommittee (RASC).  MISO commendably adapted participation models and other aspects of their proposal based on Stakeholder feedback.

Unfortunately, the final design details of MISO’s proposed accreditation methodologies were not available until 11/6 when it published its Load Modifying Resource Reforms Draft White Paper (Version 2), and several aspects of that accreditation mistreat dispatchable Behind the Meter Generation (BTMG) or are otherwise counterproductive.

1. The one (1) year lookback period for accreditation of Non-Intermittent BTMG may distort a resource’s accreditation by understating its contribution to reliability if, for instance, it experiences one significant forced outage.  MISO inadvertently acknowledged as much in its presentation, “20241106 RASC Item 08ai LMR Reforms (RASC-2019-9).pdf”, where Slide 23 listed a 3 year lookback period (while slide 16 used 1 year).  Since BTMG are accredited only during Capacity At Risk Hours and Tier 2 Resource Adequacy Hours, as few as 65 hours per season will be used (note from PY’19’20 – PY’22’23 in MISO N/C there have been 2 instances of > 65 hours in Fall and 2 instances in Summer).  Thus, if a dispatchable thermal BTMG experiences one forced outage that extends over most or all of the 65 hours used for accreditation in a given season, it will forfeit most/all of its accreditation for that season in the next PY (as well as face penalties, addressed below). A dispatchable thermal resource is the same whether registered at MISO as a Generation Resources or a BTMG: a machine that can break down despite excellent maintenance and care.  The 1 year lookback discriminates against dispatchable BTMG when Schedule 53A Resources have a 3 year lookback.
2. LMRs must be accessible 24/7 as availability is uploaded for every hour of the year. Since the day and time of the reliability event is not known beforehand, this is an empirical fact that MISO seems to miss when representing that LMRs only need to be available in an emergency.
3.  MISO does not plan to give outage exemptions to BTMG. Yet MISO expects BTMG to forecast the Capacity At Risk Hours and Tier 2 hours to be able to plan outages or face accreditation issues. This is exacerbated when only doing a 1 year lookback for accreditation.
4. Continuing with the example in 1 above, if a dispatchable thermal BTMG experiences one forced outage that extends over most/all of the 65 hours used for accreditation in a given season, MISO will set the accredited value of this resource to zero for the Season and MISO may disqualify the resource for the remainder of the Planning Year (PY).  When combined with 1 above, this draconian penalty could wipe out a dispatchable BTMG’s accreditation for an entire season for 2 PYs, and the balance of the current PY, all because of 1 forced outage.
5. As a separate example, a dispatchable BTMG that was derated and hence partially responded to deployment during an Emergency ( ≥ 50% Capacity Availability and < Tolerance Band per proposed Tariff 69A.3.9) would be subject to Deficient Energy outside Tolerance Band if registered as a DRR or replacement energy costs if registered as an LMR.  That dispatchable BTMG would also be subject to a penalty in the amount of the ratio of the demand reduction not achieved times the enrolled capacity rating times the Auction Clearing Price (ACP) for each Season for the remainder of the Planning Year, or until such resource fully performs in response to a subsequent Scheduling Instruction or test.  All those penalties would be in addition to the reduced accreditation in that season in the next PY.
6. Penalties for Capacity Availability above the upper bound of the Tolerance Band make no sense during system conditions at or above Capacity Advisory, as other dispatchable resources can be directed to reduce output, thereby creating additional Operating Reserves.
7. How is “Firm Service Level: The amount of customer Load, in MW, that is intended to always be consumed by an end use customer” determined? (Tariff Module A)

MISO’s current LMR proposal thus violates 4 of its 5 Market Design Guiding Principles:

1. Support an economically efficient wholesale market system that minimizes cost to serve load

2. Facilitate nondiscriminatory market participation regardless of resource type, business model, sector or regional location

4. Support Market Participants in making efficient operational and investment decisions

5. Maximize alignment of market requirements with reliability requirements of the system

Just as dispatchable resources are retiring, removing necessary system attributes while being largely replaced by intermittent resources with fewer or none of those attributes, MISO’s LMR proposal threatens the accreditation of dispatchable BTMG resources.  As it currently stands, MISO’s LMR proposal will reduce reliability and raise costs by pushing legitimate LMR capacity into retirement/non-participation, thereby forcing MPs to replace this capacity at a time when planning reserves are declining and building new capacity resources is difficult as well as costly.

Please note that Lansing Board of Water and Light & The City of Ames support this feedback.

Thank you for the opportunity to provide feedback on this important issue of LMR reforms.  In addition to those companies noted in Michigan Public Power Agency's (MPPA's) submitted feedback, IMEA and CMPAS also support MPPA's feedback.

MGE supports the feedback provides by MPPA.  

In addition, please address the following questions/concerns regarding your LMR proposal:

1. Testing: Will a test initiated by the Market Participant satisfy the annual testing requirement for DRRs and LMRs?
2. Must Offer Requirement: For LMRs that clear the PRA, how will the required must offer MW be administered?  Is there an allowance for conditions such as ambient weather and time of day?
3. Test Criteria: When assessing resource performance under a test, will there be an allowance for prevailing conditions that could reasonably explain performance less than the accredited value? 

CMPAS appreciates the chance to comment, now that final design materials have been released.

The December 4, 2024 deadline asks for feedback on proposed accreditation methodologies, proposed participation models, proposed testing and penalties, and tariff redlines. We note the additional December 9 comment deadline MISO has for stakeholder feedback on the LMR Accreditation Tariff and will provide comments on specific tariff language/redlines, including redlines regarding the proposed accreditation methodologies under that deadline, as necessary. For December 4, feedback includes:

#1) More Time To Understand MISO Proposals: CMPAS asks for more time for stakeholders to understand the final materials submitted by MISO on November 6 and November 19. The final design and tariff redlines for these proposed reforms are complex and multiple opportunities to ask questions, over repeated meetings, are necessary as opposed to a couple of weeks. We support other stakeholders who have asked for additional time and multiple additional RASC meetings prior to LMR Reform proposal filing with the FERC.

Proposed Participation Models and Proposed Testing & Penalties

We continue to have several concerns about the choice of 30 minutes as the response time requirement DRR Type-II and LMR Type-II participation models, especially starting in MISO PY 2028/2029. Our comments here should not be construed as supporting this choice by MISO.

However, if MISO insists on sticking to this design and its currently proposed timeline for implementation, MISO should also provide as part of its proposal indicative timelines for when operational materials will be released. Such operational materials include but are not limited to redlines to applicable Business Practice Manuals (as draft Tariff materials mention BPM changes), a MISO/DSRI API interface solution, and detailed hourly examples of Capability calculations for all resource types (see note* at bottom). It is clear from the materials posted in November that MPs need these operational materials in addition to tariff redlines in order to be able to choose between participation models. MPs need these materials well in advance of MISO PY 2028/2029 and need to know when to expect them.

*Note: For example, the most detailed examples of Capability calculations in the LMR Whitepaper Version 2.0 – those containing tables of numerical data for several hours – are exclusively for Demand Resources. While the examples mention that “a BTMG will be subject to these same rules”, some of the terminology in these examples, such as “Metered Load”, do not apply to all participation models open to a BTMG. As such, explicit numerical examples featuring other resource types, including BTMGs, should also be provided.

DTE appreciates the opportunity to provide feedback on MISO’s Load Modifying Resource (LMR) reform proposal. As stated in previous feedback, DTE agrees that some degree of reform is required for both LMR participation and accreditation, however we have concerns regarding the current proposal and offer the following comments:

Deployment

DTE has concerns with the proposed deployment of LMR Type-I resources during the Maximum Generation Alert stage. At this stage there is still a positive reserve margin on the system, indicating that economic resources are still available to MISO. MISO should not call on Demand Response and curtail customer loads before using all available economic resources. DTE would be comfortable with LMR Type-I resources being deployed either (1) during the Maximum Generation Warning stage or (2) if MISO reworked their emergency procedure to ensure all economic resources are deployed during the Maximum Generation Alert stage before Demand Response is used.

Accreditation

DTE approves of the direction MISO is taking towards aligning accreditation of LMRs with actual availability during the riskiest hours instead of availability during the MISO coincident peak. However, since capacity advisory hours will now directly impact accreditation of LMRs, DTE recommends that MISO more diligently declare capacity advisory events so that they do not persist overnight when they are not necessary. This will ensure that LMR programs are not negatively affected by capacity advisory hours that occur when there is no true system risk.

DTE also recommends that MISO remove the 30MW cap on the tolerance band. There does not seem to be tangible benefit to capping the tolerance band, and the only consequence of that cap will be to incentivize LMRs to register so that their availability does not cause them to exceed the 30MW cap.

Testing

DTE would like MISO to clarify in the testing procedure if all LMRs owned by a single market participant will be tested at the same time or if MISO will test each LMR at separate times.

Participation

DTE has concerns about the AME resource proposal, where every resource that offers Emergency commitment status 5 times in the Day Ahead market or 110 hours in the Real Time market will be considered an AME resource next year. DTE believes that this is reactionary and will not accurately represent resources that should actually be classified as AME. For example, consider a peaking unit that needs to be offered as emergency for several days due to approaching emission limits for a given year. However, the following year, the same peaker accrued fewer run hours and was not required to be offered as emergency as it was not approaching its run hour limit. Under the current proposal, this resource would have been accredited as a Schedule 53A resource the year it was offered with emergency commit status, and then accredited as a Schedule 53B AME resource the year it was not offered with emergency commit status. DTE recommends that MISO add to their process a step to discuss the AME resource designation with the resource owner each time it is applied by MISO to ensure that the status is applied in an appropriate manner. Additionally, setting the emergency commit status limit at 5 times or 110 hours seems arbitrary and strict. Instead, DTE recommends setting the emergency commit status limit at 31 days, similar to the planned outage limits before the CRNCC penalty begins accruing damages.  

Attachment TT and DRR Tariff language

When discussing and figuring out the meter data retention requirements, MISO should determine which is more important, granularity of the data or the length of time it is retained. In the DRR tariff proposal, MISO suggests retaining meter data for five years but does not state the desired granularity.  DTE supports the data retention efforts but urges MISO to require no more granularity than 30-minute intervals and to limit retention to 18 months of history.  Any requirement above 18 months would require significant investment and processing capabilities added.

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

DTE has nearly 350,000 residential customers that participate in DR programs. Collecting 30-minute intervals for this amount of customers would total 6,132,000,000 data points in a single year. This value can be cut in half if 60-minute intervals would suffice but would double if 15-minute intervals became the requirement. Furthermore, because of how residential customers enroll and unenroll in these programs, 30-minute functionality would have to be turned on for all residential customers to assure 30-minute data is available for all participating customers in a DR program. DTE serves 1.9 million residential customers. One year of 30-minute intervals would total 32,775,000,000 data points. Processing this amount of data on an annual basis, and potentially adding new technology to enable the collection of this data would likely be cost prohibitive to DTE and other MISO participants.

A possible solution to the processing of this amount of data would be to design and implement a statistically significant sample and provide sample data to MISO. DTE supports this solution and would be willing to design a sample, deploy the sample and collect 30-minute data to provide to MISO. However, in Attachment TT MISO is proposing requiring a new sample to be drawn every month. From a sample design perspective, this frequency of deploying a new sample is unnecessary. While DTE acknowledges that samples decay over time, the cost and benefits of resampling needs to be weighed against the cost and benefits of maintaining the existing deployed sample. To ease MISO’s concern about the seasonality, DTE would support deployment of four different samples, one for each season. Additionally, DTE would ask for the sample to be refreshed no more than once every three years unless the Company has observed a large change in the population resulting in a need to resample sooner. The burden of refreshing a sample more frequently would not add any additional value.

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

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

The Entergy Operating Companies ("EOCs”)[1] appreciate the opportunity to provide feedback on MISO’s Market Redefinition Accreditation reforms for LMRs. 

Proposed Accreditation methodologies

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.  The EOCs request that DRR and LMR instruments utilize a look back period of three years so that a larger sample size is acquired for the accreditation calculation resulting in more accurate and stable accreditation ratings. Further, using a three year look back period would align DRR and LMR resources with how other resource types under SAC are currently accredited.  

Proposed Participation Models

In general, the EOCs agree with the current proposed participation models presented by MISO. We agree that accurate availability, accreditation, and operational effectiveness should be the three major focus areas of the current LMR reform effort. We appreciate that MISO understands that accreditation and capability depend on how the resource is enrolled and provides avenues for these resources to participate in the demand response program and that the methodologies of accreditation have changed for these resources.

MISO appears to have a firm view that LMR Type 1 should be deployed before Event Step 1 (EEA Level 1) is reached; the EOCs continue to disagree with that approach and would prefer that MISO defer deployment of LMR Type 1 resources to Event Step 1 (EEA Level 1) after emergency resources and emergency limits are activated.  Nonetheless, if MISO maintains its current proposed approach, the EOCs believe that the LMR Type I deployment notification process should only begin during a Max Gen Alert stage when MISO is forecasting that at least an Event Step 1 stage will be reached. Further, the EOCs believe that prior to the time of LMR Type I resources curtailing load, other emergency steps should have already been utilized (e.g. external resources scheduled in, exports curtailed, emergency resources committed). Said differently, the EOCs believe that MISO should aim to avoid scenarios where LMR Type I resources are notified and deployed during the Max Gen Alert stage, and a Max Gen Warning or higher step never occurs. The EOCs understand that there is uncertainty with forecasting grid conditions and that this scenario cannot always be avoided, but we request that MISO state this intent in the FERC LMR reform filing and establish criteria for grid operators to follow so that LMR Type I resources are deployed with the goal of achieving this intent.   

Under the current proposal by MISO, intermittent BTMG, non-intermittent BTMG, and AME resources currently do not receive planned outage exemptions. The EOCs do not agree with MISO’s rationale for why these resources do not qualify for such exemptions and do not see why planned outages for these types of resources should be treated differently than planned outages performed by conventional thermal resources.  The EOCs urge MISO to reconsider its approach on this point.

Proposed Testing and Penalties

In general the EOCs agree with the current proposed testing criteria for DRR and LMR Type 1 and Type 2 units that was outlined at the November RASC meeting, with no changes to the current testing of BTMGs.

Resource Accreditation 

MISO’s proposal for accrediting new LMR/DRR resources involves the use of an expected daily load factor where all hours of the day are equally weighted in determining the load factor. Given that the capacity at risk and Tier 2 hours are more concentrated in the daytime hours, using an equal weighting of hours will likely underestimate the load levels during the hours where LMR/DRR resources will likely be deployed. The EOCs believe that MISO should allow new LMR/DRR resources to develop a load factor based on the historic distribution of “capacity at risk” hours and “Tier 2” so that the expected load during the accreditation hours will carry a higher weight than the non-accreditation hours.

 Tariff Redlines

The EOCs will provide comments for this topic in our feedback for the RASC: LMR Accreditation Draft Tariff (RASC-2019-9)

Voltus comments to RASC on RASC: LMR Reforms (RASC-2019-9) (20241106)

December 4th, 2024

On November 6^th, MISO presented to the Resource Adequacy Subcommittee and provided additional details regarding their proposals for capacity accreditation and participation for LMRs and demand resources in MISO’s footprint. Voltus appreciates the opportunity to comment on these proposed changes. 

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

MISO’s proposal is still too unclear to support a Tariff Filing in Q1 2025

While LMR reforms is a topic that MISO has discussed at the RASC for some time, in more recent meetings of the MISO RASC (since August) MISO has revised key facets of its proposals multiple times and, as described infra, many critical details of these proposals are still unclear or, in some cases, flawed. MISO should provide appropriate examples of how resources would receive accreditation and participate as capacity resources under its latest proposals, and consider hosting a workshop for their final proposal before proceeding with a Tariff filing.

Namely, MISO must provide better examples of its proposed “rules around resource definition and history”, Measurement & Verification for assets on the Firm Service Level baseline (as discussed below), and circumstances under which it is appropriate to disqualify LMR-I and DRR resources that are unavailable for a deployment. Without these key details of MISO’s proposal clearly spelled out, stakeholders cannot effectively provide feedback to MISO – and MISO therefore cannot effectively consider feedback prior to a Tariff filing.

MISO’s proposal for which hours to include for the determination of DR availability do not result in accreditation that is actually commensurate with value to MISO during emergencies

MISO’s proposal to base DR accreditation on Capacity Availability during all Capacity At Risk and Tier 2 RA hours is an improvement over previous proposals, but still does not accurately capture the value of DR resources during capacity emergencies.

It is reasonable for MISO to include both Capacity At Risk and Tier 2 RA hours, since emergencies may not always be predictable. However, MISO should weight the value of Capacity Availability to have a higher impact on a resource’s accreditation during highest-risk hours.

As an example, consider a university registered as an LMR whose load is HVAC driven. Such a resource is unlikely to have much load (and therefore Capacity Availability) in morning or overnight Tier 2 RA or Capacity at Risk hours, but will likely have significant curtailable load during the hours in which it is most likely to be needed - the hottest hours of the afternoon. Under MISO’s current proposal, its availability at 5pm is weighted exactly evenly as its availability at 6am, if that 6am hour is a part of a Conservative Operations Alert. Clearly, though, this asset’s value to MISO’s system is likely higher at the 5pm hour.

To account for this, MISO should weight capacity availability in accordance with operating margin during Tier 2 RA and Capacity At Risk hours. For example, MISO could base 30% of a resource’s accreditation on its availability during the 10/65 hours with the tightest local operating margins, the next 25% on the next 10/65 hours, and so on. 

With this approach, MISO would be appropriately assigning capacity accreditation according to asset capability during the hours in which those resources are most needed.

MISO’s proposal to rely on load-factor for DR accreditation is flawed and punitive for resources with low load outside of peak hours

In the event that there are fewer than sixty five (65) Capacity At Risk and Tier 2 RA hours in MISO’s lookback for determining accreditation, MISO proposes to calculate an assumed availability for those deficient hours as load factor x maximum load - FSL. However, the use of a 24-hour load factor is likely to produce inaccurate results, because customer load outside of peak hours (say, from 2-3 am) will affect accreditation calculations, and thus could result in either over- or under-accreditation of a resource.

As a simple example, suppose a resource can curtail to a Firm Service Level of 0 MW in response to MISO scheduling instructions, and has a 50% load factor with 10 MW of load from 8 am - 8 pm each day and 0 MW of load from 8 pm - 8 am. Despite reliably having 10 MW of availability during day-time hours, MISO’s calculation would assume only 5 MW of availability for deficient hours. Conversely, if the load availability were overnight rather than day-time only, the resource would incorrectly be accredited with 5 MW of availability for deficient hours, rather than the correct value of 0 MW. In the real world, any HVAC curtailment will resemble the first example here, and will have its accreditation inaccurately de-rated due to this calculation.

Instead, similar to the above proposal, if MISO has only N Capacity-At-Risk and Tier 2 RA hours such that N<65, MISO should allocate additional hours to meet the 65-hour threshold. This can be done by incorporating resources’ load minus FSL in the next 65 - N hours with the tightest operating margins, excluding the already-included Capacity-At-Risk and Tier 2 RA hours. The updated formula for calculating DR ISAC has been attached as supplemental feedback.

This will more accurately reflect resources’ capabilities in the hours where MISO is most likely to need them – those with the tightest operating margins.

MISO’s proposal around Resource Definition is unclear and, in general, defeats the purpose of having aggregated LMRs

In MISO’s white paper, MISO discusses the concept of “resource definition and history” as something that will be further clarified. However, MISO also outlines that “aggregations will now be defined in terms of a Market Participant and location rather than re-registered each year as the underlying aggregation changes. The history of the resource will continue even as the aggregation changes and Market Participants are encouraged to enroll each type of aggregation as a separate LMR rather than a single LMR.”

Without further clarity on what MISO means by this statement, it is difficult to provide substantive comments on this proposal. For example, if MISO contends that the history of an individual location will continue over time - does this then require Capacity Availability to be submitted to MISO for each individual location registered within an aggregation? 

MISO should avoid further dividing LMRs by “resource definition” and inhibiting the ability of assets to aggregate for performance evaluation. Distributed resources, including demand response programs, are most predictable and reliable when aggregated as broadly as possible. The load of singular resources, particularly in industrial segments, is difficult to predict and represent to MISO operators via availability. However, the load and curtailment capability of large aggregations of resources across numerous industries and asset types is much easier to forecast. In addition, broader aggregation of LMRs incentivizes overperformance of individual facilities, as MPs can compensate them for offsetting underperformance of other individual facilities. 

Instead, MISO should evaluate performance of LMRs in the same way that they are dispatched - by Market Participant and LBA, and leave the decision of how broadly to aggregate registrations themselves up to MPs, whose assets will be accredited in line with this proposal according to their availability and who have the best information about the predictability of the load profiles of their assets. 

MISO’s proposal for FSL M&V is unclear, but could lead to inaccurate measurements of LMR performance

MISO has proposed to add language to Attachment TT stating that, unless another methodology is approved, “Measurement and Verification for Firm Service Level LMR participants will be based upon actual Metered Load in the Hour immediately preceding notification to the Firm Service Level participant of the Scheduling Instruction by the Transmission Provider”.

This language appears problematic. Consider an HVAC-based resource with an FSL of 500 kW with 6-hours notification timing: at 8am, with no HVAC running, the asset will likely be using only its non-curtailable 500 kW. However, at 3pm, the HVAC equipment will be running, and the asset may typically have a load of 1000 kW. 

If this asset receives scheduling instructions from MISO at 9am to curtail its available 500 kW by 3pm, and the asset does curtail from 1000 kW down to its FSL of 500 kW, it will have provided 500 kW of relief to MISO. However, the proposed language in Attachment TT would appear to compare the load during the event with the 500 kW used at 8am – a performance of 0 kW vs scheduling instructions of 500 kW.

MISO has not included any examples of how this M&V methodology is proposed to work - so it is unclear if this is MISO’s intent or not.

In any case, MISO should instead create a baseline for hourly load using a similar methodology as for Seasonal Capability – that is, for each hour, use the average of the top 20% of Load consumed in the Season, and subtract load in the event from these values to determine hourly performance. In this way, resources that reach their FSL and submit Availability that is within the tolerance band of their Seasonal Capability will be meeting Scheduling Instructions.

Determining M&V in this way would also provide consistency with the way that Capability is determined in hours where an asset is below its FSL – that is, Capability and performance would be identical. This alignment will drive clarity to MPs and Operators alike in the value that a given asset has to the System regardless of if an event is called or not. 

LMR-Is should not face potential disqualification for participating as intended in MISO’s proposal

In MISO’s white paper, MISO outlines that LMR-Is that “[submit] zero availability during at least one LMR deployments, even if only one occurs, may result in disqualification of the asset as if it failed to perform.”

LMR-Is, definitionally, are Planning Resources - as such, it’s reasonable for MISO to require that LMR-Is do demonstrate availability during Capacity At Risk hours once registered and are available for dispatch at a minimum of one time. However, MISO has spelled out that the point of the LMR-I instrument is that it may limit its deployments at the cost of capacity accreditation. To this end, MISO should clarify that such penalties and risk of disqualification only apply if an LMR-I is never available during seasonal LMR deployments.

MISO’s proposals regarding the Tolerance Band for Capacity Availability are reasonable

Voltus supports MISO’s latest proposals regarding the use of the Tolerance Band for LMR and DRR Availability and Performance.

Respectfully Submitted,

Sean Shafer

Energy Markets Manager

Voltus, Inc.

WPPI offers the following comments on developments on MISO’s LMR reform proposal from the November RASC meeting, with a focus on V2 of the white paper, which we understand MISO plans to update.  We are separately providing comments on the draft tariff language under RASC: LMR Accreditation Draft Tariff (RASC-2019-9) for which comments are due December 9.

1. WPPI supports the comments of MPPA.  Concerns about availability of behind-the-meter generation should be handled via accreditation—as it is for other generating equipment—and not via disqualification for performance that reflects fundamental limits on performance of such equipment.  MISO appears to suggest that different treatment is appropriate because LMR deployment is close to the last option available to operators before shedding firm load.  We find this fact irrelevant to the question of the proper treatment of BTMG, which should align with that of other physical generation equipment.
2. WPPI supports the comments of ABATE et al.  In particular, MISO needs to clarify the conditions under which annual—as opposed to triennial testing—would be required (with no opt-out provision).
3. Reviewing MISO’s posted Demand Resource Accreditation Example spreadsheet, we note that the RA Hours listing for Fall 2022 appears to show discrepancies with respect to the posting available under PRA Documents on MISO’s website.  We would ask MISO to explain any differences between these data sources.  We would also ask that MISO, in future spreadsheet posting, refrain from making such spreadsheets password-protected, which complicates use by stakeholders.  Instead, we suggest that MISO simply protect the spreadsheet without using a password, which would allow users to unprotect if desired for their own purposes.
4. Regarding the posted white paper (V2), we ask MISO to seek to eliminate inconsistencies between the white paper and the proposed tariff changes, to avoid confusion.
5. MISO describes in Table 1 of the white paper that LMR availability reporting can be done via the DSRI tool.  MISO should also accommodate direct meter-data reporting via ICCP, with the ability to apply registered Firm Service Level and thus calculate resource availability in real time.  This will provide MISO operators with the best current data and greatly facilitate provision of this data by Market Participants.  We recognize that establishing this capability will require some time, but this would appear entirely feasible by June 2028.  This is consistent with comments made by WPPI at the October RASC meeting and with both WPPI’s and AECC’s written feedback comments following that meeting, but we are unaware that MISO has provided any formal response to this proposal.
6. At p. 2 the white paper says that LMR – Type I resources “must respond to at least one Scheduling Instruction per season if instructed, or risk reduced accreditation.”  This description implies that LMRs that do respond to one scheduling instruction per season do not risk reduced accreditation, which we understand is not correct, as the actual consequences of failing to respond to even a single SI in a season are more severe than reduced accreditation.  Also, “if instructed” seems redundant in reference to a scheduling reduction.
7. At p. 9 the White Paper notes that the proposed removal of operational limits “reflects operational concerns regarding having to decide if an Emergency warrants deployment or if it is better to wait to deploy these Resources for a future Emergency.”  While we believe MISO’s current proposal may be reasonable, we find this rationale unpersuasive.  Specifically, we remain to be convinced that resource availability for potential future events is an appropriate operational concern.  We note that, in any case, MISO’s proposed solution does not really solve this problem, since Type I LMRs will still be able to decide whether to make themselves available for more than one deployment, without providing MISO of notice at the time of registration.
8. At pp. 8-9 the white paper cites the IMM’s statement that roughly 48% of LMRs are dual-registered as EDRs and that this registration approach “is an effective strategy to receive capacity payments with virtually no chance of having to perform.”  The IMM exaggerates, and the White Paper should not uncritically repeat these claims.  What may have had some validity with a 1% dual-registration rate becomes increasingly implausible with higher rates.  Logically, the larger the share of LMRs that are dual-registered, the higher the likelihood of these being called.  Where roughly half of LMRs are dual-registered, usage rates for dual-registered resources should approach those of other LMRs. 
9. At p. 9 the White Paper says that “For a DRR or an LMR – Type I resource, MISO will require participation in at least one event in a Season that involves deployment of LMR – Type I resources within the same Local Balancing Authority Area, voluntarily or through Scheduling Instructions.”  We read this to say that an LMR that properly reports availability but that is not deployed when other LMRs in the LBAA are deployed should nonetheless deploy, if it has not previously deployed in that season.  A similar statement appears at p. 13 (“MISO will require DRR and LMR – Type I resources to respond to at least one Scheduling Instruction issued to LMR – Type I resources per Season, if a Scheduling Instruction is issued”).  This appears problematic for several reasons, including that it could lead to over-response of LMRs that MISO has indicated it wants to avoid and that it could reduce availability of resources for future capacity emergencies.  We expect that it will make sense in some circumstances to request only partial deployment of LMRs in a given LBAA.  We ask MISO to provide clarification and, if this is indeed MISO’s intent, to provide a substantial rationale for this proposed rule.
10. At p. 9 the White Paper notes that the proposed removal of operational limits “reflects operational concerns regarding having to decide if an Emergency warrants deployment or if it is better to wait to deploy these Resources for a future Emergency.”  While we believe MISO’s current proposal may be reasonable, we find this rationale unpersuasive.  Specifically, we remain to be convinced that resource availability for potential future events is an appropriate operational concern.  We note that, in any case, MISO’s proposed solution would not effectively solve this problem, since Type I LMRs will still be able to decide whether to make themselves available for more than one deployment, without providing MISO of notice at the time of registration.
11. The white paper provides some accreditation examples at pp. 19-20.  We ask MISO to revisit these examples to ensure that all relevant information is included.
12. At p. 24 the white paper says that “A lookback of one year, rather than three, is necessary because these resources are allowed to submit unavailability for an event during the Planning Year. By using a three-year look-back, the signal sent by reduced Capacity Availability will be attenuated resulting in too much accreditation for these resources.”  We don’t find this persuasive.  Determining the look-back period always involves a tradeoff between currency and volatility.  There is no reason why a particular choice is “necessary.”  Please consider providing a fuller explanation for MISO’s proposed choice.
13. The white paper includes a numerical example in the discussion of the tolerance band at p. 27, which includes “100 MW (120 MW – 8 MW)”—an apparent arithmetical or typographic error.
14. At p. 30 the white paper says “Without 5-minute meter data submitted for resources with short response times, the LMR – Type II resource would become, as a practical matter, a 90-minute product due to the timing of the deployment instructions and the metered data.”  We are perplexed as to how a possible 10-minute difference in meter-data interval could lead to a 30-minute resource becoming a 90-minute resource.
15. At p. 31 the white paper says that “If a resource does not provide a response consistent with any Scheduling Instructions issued within a Season within the same LBA, MISO will set the accredited value of this resource to zero for the Season and MISO will initiate an investigation with the Market Participant into the cause of the resource being unavailable.”  To the extent this is intended to apply to behind-the-meter generation, it appears wholly unreasonable.  Like any generator, BTMG are subject to failure, and this should be accounted for in accreditation rather than insistence on perfect performance.
16. At p. 34 the white paper includes the following paragraph:
    1. Because of this procedure, demand can experience potentially large swings in the times it is needed, potentially destabilizing the results during Seasons with a very low count in the number of EUE hours. Therefore, it is inappropriate to use the LOLE model to help determine accreditation, as is done for Generation Resources.

We don’t understand what MISO is trying to convey here, and ask MISO to provide a fuller explanation to the extent this point is included in the next version.