RASC: New Issue Assignments (20240117)

Both of these issues should be accepted by the RASC, placed on its management plan, and scheduled for discussion as soon as feasible. They contribute to the Reliability Imperative by removing inefficiencies and obstacles to registering additional resources.

WEC Energy Group supports the Voltus Issue Submission to the RASC on improvements to the capacity replacement process.  In addition to the timing of replacement capacity enrollments, we support a thorough review of the enitre capacity replacement process including the ability to enter intra-seasonal start and stop dates, automatic assignment of capacity back to the seller at the stop date, and the burdensome 7-day gap between the replacement submission and the start date where the capacity is useless to either party.

Advanced Energy Management Alliance

MISO Resource Adequacy Sub-Committee (RASC)

“New Issue Assignments (20240117)”

February 9, 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 on the new issue submission by Voltus at the January 17, 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 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 January 17^th meeting of the RASC, Voltus introduced two new topics for MISO and the RASC to incorporate into the RASC management plan. The topics focus on Assessing LMR Registrations at a Locational Basis and Timing of Mid-Year Replacement Capacity Enrollments. AEMA supports incorporation of these two recommendations into the RASC management plan and offers the following comments:

• Assessing LMR Registrations on a Locational Basis: Voltus has proposed aligning the LMR registration and review process between the Local Balancing Authority (LBA), Load Serving Entity (LSE), Relevant Electric Retail Regulatory Authority (RERRA), and MISO so that the location-by-location review by the LBA, LSE, and RERRA is also utilized by MISO in their acceptance/rejection of the enrollment. The recommendation would shift the MISO review from a broad rejection/acceptance at the enrollment level to acceptance/rejection at the locational level as completed by the relevant entities. The recommendation from Voltus that MISO only rejects the specific locations flagged by the LBA, LSE, and/or RERRA and approves the balance of the registration makes sense, removes duplicative work, and makes the process more efficient. MISO should pursue implementing this recommendation as a high priority.
  
  
• Mid-Year Replacement Capacity: Voltus has proposed that MISO modify as needed, the rules governing the registration of Mid-Year Replacement Capacity, so that a resource may be registered in anticipation of being utilized as replacement capacity, as opposed to being limited to registering only after a replacement capacity need is identified. This simple change to the process would allow potential resources to register ahead of identified needs, creating a more efficient and simpler process for market participants to access these resources. Since this change would be a relatively simple implementation, AEMA requests that MISO make this efficiency improvement a high priority and implement the modification for the upcoming 2024/2025 Planning Resource Auction.

AEMA appreciates consideration of these comments by the RASC and MISO staff as part of improvements to the Resource Adequacy design 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

[1]  For additional information, see AEMA website: http://aem-alliance.org

[2]  20240117 RASC Item 06 Issue Submission - Voltus Assessing LMR Registrations on a Location Basis.pdf and 20240117 RASC Item 06 Issue Submission - Voltus Timing of Mid Year Replacement Capacity Enrollments.pdf   

WVPA supports adding the following issues to the RASC management plan:

1) Timing of Replacement Capacity Enrollments and

2) Location-Based LMR Approvals

AMES, AMP and IMPA generally support WPPI's feedback; AMES and IMPA also support MPPA's feedback.

I'm happy to discuss.

David Sapper

dsapper@ces-ltd.com

WPPI supports adoption by RASC of the issue seeking less-constrained mid-year Resource registration, and we note that improvements in this area would align with the goal MISO has articulated of providing resources with incentives to be available during periods of highest need.  We don’t take a position on appropriate resolution of the ARC-registration issue, but this appears to be an appropriate issue for consideration by RASC.

In the January 17 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were presented with two potential new issue assignments from Voltus: 1) Timing of Replacement Capacity Enrollments and 2) Location-Based LMR Approvals.  Stakeholders are asked to provide feedback on whether these issues should be accepted by the RASC for placement into the management plan.  

The issue raised by Voltus regarding replacement capacity enrollments highlights what appears to be an artificial constraint on needing to define a counter-party when registering a resource.  I don't think we need to spend much time at the RASC on this, but we should simply bring up the issue, approve the most flexible registration methodology (high value in bringing more replacement capacity to the market, given the need for replacement capacity for longer planned outages).  

the issue of location based LMR approvals is more complicated for programs with a large number of customers for a given program, such as a residential cycled air program.  Again, the requirements need to take into account the full range of programs being offered and not impose a reporting requirement that is too difficult to fulfill.  

DTE appreciates the opportunity to provide feedback on two proposals from Voltus. In Voltus’ proposal on Location-Based LMR Approvals, Voltus states that after a single location is rejected that the remaining approved locations proceed along the ARC registration process with no need for further MP review. This portion of the proposal could create issues within our service territory as our State requires each ARC registration meet specific MW requirements. If the rejection of a single location drops the entire registration below that MW requirement, then the remaining locations should not be allowed to continue on the ARC registration pathway. DTE recommends that if MISO continues with this proposal by Voltus that they include the ability to review kW and MW of all individual locations attached to a single registration so that when a location is rejected, the entire registration can be re-validated. This ensures the registration meets state requirements. In addition, if a location is rejected, there should be a validation that the LMR that was provided to MISO does not include the rejected account.  The process is currently manually intensive, and this would address any human performance issues as well as provide all parties the final approved registration.  

DTE also recommends that MISO streamline the ARC registration process by creating a tool on the MISO portal that allows access to current planning year registration detail. This detail would include current approval status of individual accounts and all registrations for the current planning year, history of activity for each account and registration for current planning year, and a data sheet containing individual meter capability and customer names in a single file. This would allow reviewers to approve and deny registrations directly in the tool instead of having track multiple emails and excel files sent from MISO.  

CPower supports inclusion of the two new issues submitted by Voltus, Inc., Timing of Replacement Capacity Enrollments and Location-Based LMR Enrollments, in the RASC management plan.  CPower shares similar concerns to Voltus on the ability to make available new DR for use as replacement capacity during a Planning Year. CPower also shares similar concerns raised in the second issue pertaining to the registration process for Demand Resources (DR), and addressing this issue within the stakeholder process will ideally result in the duplicative work needed by all parties involved in the registration review process for LMRs (as well as for DRR and EDR).CPower recommends these issues be added to the management plan and scheduled for discussion as soon as is practical.

Comments

of the

Association of Businesses Advocating Tariff Equity (ABATE),

Illinois Industrial Energy Consumers (IIEC),

Louisiana Energy Users Group (LEUG),

Texas Industrial Energy Consumers (TIEC),

Coalition of MISO Transmission Customers (CMTC),

Midwest Industrial Customers (MIC),

and

NIPSCO Large Customer Group (NLCG) [1]

Regarding

RASC: New Issue Assignments (20240117)

February 9, 2024

ABATE, IIEC, LEUG, TIEC, CMTC and MIC, as representatives of the End-Use Customer (EUC) Sector, and NLCG appreciate this opportunity to provide comments to MISO.

During the January 17, 2024 meeting of the Resource Adequacy Subcommittee (RASC), stakeholders were presented with two potential new issue assignments from Voltus: 1) Timing of Replacement Capacity Enrollments and 2) Location-Based LMR Approvals.  MISO has asked stakeholders to provide feedback on whether these issues should be accepted by the RASC for placement into the management plan.  These comments respond to that invitation.

The EUC Sector members participating in these comments support the RASC accepting both of the issues raised by Voltus and placing these issues on the management plan for the RASC.

Providing additional flexibility with respect to allowing mid-Planning Year Planning Resource registration, including new Load Modifying Resource (LMR) registration, at any time during a Planning Year and not just after there is a need for replacement capacity, will act to improve resource adequacy within the MISO footprint when events occur that require capacity replacement by making additional capacity supplies available that might not otherwise be available.

Reforming the process of approving aggregated LMR registration -- such that an aggregated LMR registration is not rejected in its entirety due to one or two disputed locations within that aggregation -- would remove an undue inhibition to the registration of aggregated LMRs with MISO, thereby increasing the amount of capacity available for resource adequacy within MISO.

For these reasons, the participating EUC Sector members support further pursuit of the Voltus proposals and their addition to the management plan for the MISO RASC.   

Thank you for providing us an opportunity to provide the above comments.  If it would be of help, we would be glad to discuss the above comments further with MISO and other stakeholders.  If you have any questions regarding these comments, please do not hesitate to contact any of the following representatives:

Jim Dauphinais

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(636) 898-6725

jdauphinais@consultbai.com

Ali Al-Jabir

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(361) 994-1767

aaljabir@consultbai.com

Ken Stark

McNees Wallace & Nurick LLC (for CMTC)

(717) 237-5378

kstark@mcneeslaw.com

Kavita Maini

KM Energy Consulting, LLC (Consultants to MIC)

(262) 646-3981

kmaini@wi.rr.com

[1] ABATE, IIEC, LEUG, TIEC, CMTC and MIC are all MISO Members in the End-Use Customer Sector.  NLCG is a non-MISO Member stakeholder whose members include large end-use customers within Indiana that are interruptible and/or have cogeneration facilities and that take service under NIPSCO Rate Schedule 831, which allows limited market purchases through Northern Indiana Public Service Company (NIPSCO). 

The OMS Resources Work Group (RWG) provides this feedback to MISO on the RASC's new issue assignments presented by Voltus. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors.

Location-based LMRs

The RWG is supportive of moving towards location-based requirements for LMRs. This would help avoid circumstances that occur today as outlined by Voltus on Slide 6. Essentially, one bad DER could cause the entire registration to be rejected or placed on hold. However, since MISO is already developing its own location-based proposal for LMRs, this new issue may be redundant. 

Slide 8 of Voltus’ presentation observes that developing a new process for ARCs to submit location-based enrollment could be a potential roadblock as the current MECT would not support this. The RWG believes that the CUS DER Registry would be a better solution that would solve multiple problems in DR and DER aggregation. With a consolidated DER registry in place, MISO may not need to upgrade the MECT or other DR tools to enable locational aggregation. The RWG stresses that MISO needs to keep ratepayer costs in mind as it considers which systems to build out and/or use preexisting third-party software. Similarly, utilities could use the CUS DER Registry instead of each utility investing millions into their own automated, secure, and streamlined software systems.