RASC: RA Risk Metrics and Criteria (RASC-2024-4)

WEC Energy Group supports MISO's continued involvement in resource adequacy metrics discussions through industry organizations like EPRI and ESIG.  However, we do not believe that a separate RASC issue and management plan item for Resource Adequacy (RA) metrics are needed at this time.  RA enhancements, such as the seasonal construct, SAC accreditation, LOLE simulation improvements, the RBDC, and the Direct Loss-of-Load (DLOL) proposal already address many of the concerns that have been identified with the 1 day in 10 years LOLE metric.  WEC Energy Group prefers that MISO and stakeholders focus their time and effort on implementing and improving these enhancements before investigating the use of different RA metrics (especially considering the staffing constraints that MISO has reported to its Board).

If the RASC stakeholder community decides to adopt a RA metrics issue, we do not believe the time line proposed by MISO is realistic (presentation of final recommendation by November 2024).  The RASC stakeholders should evaluate and propose a more realistic time line.

MidAmerican Energy appreciates the opportunity to provide feedback RA Risk Metrics and Criteria (RASC-2024-4).

MISO should not unilaterally do any work on this issue. As the NERC report clearly states, NERC should lead an effort to come up with metrics. Those metrics need to be uniformly applied throughout the NERC footprint. If the system reserves continue to dwindle, the alignment of resource adequacy metrics throughout NERC are a necessity to prevent entities from switching from one RTO to another depending on the financial impact to those entities. MISO should encourage those efforts at the NERC level and have someone from MISO and/or OMS participate in those efforts and reports to the RASC and encourage feedback as issues are being discussed at the NERC level. MISO also needs to keep in mind that states are responsible for resource adequacy via the Energy Policy Act of 2005.

Wabash Valley Power Alliance (“WVPA”) appreciates the opportunity to comment on MISO’s exploration of different metrics for resource adequacy. WVPA understands that this issue is being explored by industry consultants. As the 1-day – in 10-year criterion is an industry standard, we believe a broader conversation should include the NERC, OMS, and other ISO/RTO stakeholder communities.

Considering the number of parties that should be involved in the resource adequacy criteria discussion, WVPA does not support placing the issue on the RASC management plan at this time. Producing a MISO-focused roadmap by the end of the year is overly ambitious, especially considering competing priorities.

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 potential exploration of Alternative Resource Adequacy Metrics (RASC-2024-4) following the August 21, 2024 Resource Adequacy Subcommittee (RASC) meeting.

Advanced Energy United (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.

Advanced Energy United recognizes the growing industry consensus that the current, long-standing resource adequacy criterion needs to be revised to better address the changing size, frequency, timing, and duration of Loss of Load events. United understands the current ongoing efforts by industry groups, such as the Energy Systems Integration Group[1] (ESIG), the North American Reliability Corporation[2] (NERC), the Electric Power Research Institute[3], as well as other grid operators, including Electric Reliability Council of Texas[4] and Southwest Power Pool[5] to develop practices that reflect these needs. For example, both ESIG and NERC highlighted that Expected Unserved Energy can aid in differentiating resource adequacy shortfalls by identifying risk not captured using other metrics. Accordingly, United supports the RASC adopting this issue for analysis provided the following concerns are addressed regarding timeline and stakeholder coordination.

At the August 21 RASC, MISO proposed the following timeline:

• August 21 RASC – Issue introduction, overview and background
• September 26 Workshop – Industry best-practices, MISO analysis and findings, analysis of alternatives, feedback request opened
• October 9 RASC – Workshop recap, presentation of hypothesis, feedback request opened
• November 6 RASC – Review feedback, presentation of final recommendation, feedback request opened

While United appreciates MISO’s interest in expediently adopting new reforms to reflect the changing nature of grid reliability risks, United strongly urges MISO to consider a longer timeline for this effort. As stakeholders expressed at the August 21 RASC, reliability standards have considerable implications in planning, operations, and accreditation. The process of analyzing potential alternative criteria, understanding their implications alongside current MISO practices, and developing effective tariff language that reflects that work must not be rushed. Stakeholders need to be given ample opportunity to coordinate with MISO on this critical workstream. This will better ensure the outcome is derived from group consensus and will also increase its likelihood of success at FERC.

When asked at the August 21 RASC, MISO stated they have no initial hypothesis as to where this analysis will lead. United appreciates MISO’s open-mindedness towards the possible solution set, but suggests MISO communicate openly and promptly with stakeholders when their analysis begins to identify possible paths forward. The more time stakeholders have to provide MISO with feedback on suggested policy, the better the eventual solution will be.

Advanced Energy United appreciates the opportunity to provide these comments and looks forward to continuing to work with MISO to explore potential alternative resource adequacy metrics in MISO. Please reach out to Conor McKenzie with any questions.

Respectfully submitted,

Conor McKenzie

202.380.1950 x3177

cmckenzie@advancedenergyunited.org

American Municipal Power (AMP) appreciates the opportunity to provide feedback on adoption and assignment of the new issue, Exploration of Alternative Resource Adequacy Metrics, to the Resource Adequacy Subcommittee, and offers the following comments for consideration.

AMP understands there may be increasing limitations with the 1-day-in-10-year loss of load expectation (LOLE) resource adequacy criterion, which is the most common resource adequacy criterion and used across much of North America. This metric only measures the frequency of outages and does not capture the size, duration, or timing of generation shortfalls.

However, given this is a common metric used more broadly by other RTOs/ISOs across the country and beyond MISO’s footprint, AMP questions if this is outside of MISO’s purview for detailed evaluation, analysis, and recommendations.

Additionally, if it is determined that it is appropriate for MISO to take responsibility for assessing potential changes in the resource adequacy criterion, it may be presumptuous on MISO’s behalf that this issue is a priority of MISO stakeholders. AMP recommends further vetting of the issue and problem statement before moving to analysis of alternatives and recommendations.

Due to competing priorities by MISO, the Resource Adequacy Subcommittee, and stakeholders, AMP also encourages MISO to reevaluate the proposed timeline, and if the issue is adopted by the RASC, delay evaluation of this issue until 2025.

This feedback is submitted on behalf of the Staff of the Louisiana Public Service Commission.  

• LPSC Staff does not oppose adoption of the Issue as long as it is limited (at this time) to the exploration and development of a report on additional resource adequacy metrics as noted in the 2023 MISO Attributes Roadmap and stated in MISO's presentation (page #3, bullet #2).
• LPSC Staff is concerned with the following aspects of MISO's presentation: 
• Slide #8 references that one of the driving criteria to pursue this issue is the MISO STI plan.  Short Term Incentives should never  be a driver for pursuit of any issue impacting stakeholders and costs.  The possible changes addressed here likely have the  potential to result in higher ratepayer costs due to changes in the resource adequacy construct.  
•  Slide #9 stipulates MISO will present a hypothesis and consider stakeholder feedback in MISO's development of a recommendation.  Furthermore, MISO will develop a roadmap to pursue the recommendation.  This process is not acceptable as MISO is basically developing its own resolutions of the proposed Issue and is not  developing a roadmap to pursue stakeholder input.  Further, this particular Issue relates to Resource Adequacy which rests with State regulatory authorities working with LSEs.  MISO's role on this Issue is as a facilitator and not the final arbiter.  LPSC staff recommends Slide #9 be reworked to acknowledge MISO's role as merely a facilitator on this Issue.
•  Slide #10 presents MISO's timeline for development and adoption of its recommendation(s).  LPSC staff recommends Slide #10 be abandoned.  An appropriate timeline can be incorporated at such point and time as the Issue is adopted and fully understood by State regulatory authorities and LSEs. 
• LPSC Staff suggests a measured approach on the part of MISO and the stakeholders to explore the gaps in the current 1-day-in-10 metric, and then an evaluation of the alternative metrics and their value to and impacts on ratepayers.
• LPSC Staff reiterates the need for State regulatory authorities and LSEs to have sufficient information, data and time to analyze the impact of any recommended reforms including the additional quantity and type of resources that may be required  - and costs of such resources.  The knowledge gained from this analysis will allow a determination of the impact on ratepayers and if these impacts outweigh any measured  benefits of revisions to resource adequacy metric(s).  
•  LPSC Staff wishes to note the "OMS 2024 Strategic Priorities" states that OMS will "Ensure any modifications to reliability requirements align with State and local planning processes and retail tariffs and consider inclusion of additional RA risk metrics."  This goal clearly notes the role of State regulatory authorities in determining what additional/modified resource adequacy risk metrics are appropriate.
• LPSC Staff strongly encourages MISO, as noted above, to adapt their presentation in a manner that is tailored to an educational and analysis approach that provides State regulators sufficient information to develop and affirm a final recommendation. 
• LPSC Staff also generally supports feedback submitted by OMS on this feedback request.

DTE appreciates the opportunity to provide feedback on MISO’s proposed exploration of alternative resource adequacy criteria. While DTE does not have a specific stance on the correct risk metric and criteria, we agree that exploration is important. Additionally, DTE believes that MISO needs to consider the issues raised by other stakeholders in the RASC. These issues include how a change in the RA metric would impact accreditation under DLOL, whether MISO and stakeholders have the bandwidth to explore this issue while managing other RASC initiatives such as DLOL, RBDC, and LMR reform, and the importance of MISO working closely with other ISOs and the OMS to determine the proper RA metric. 

The Entergy Operating Companies ("EOCs")^[1] appreciate the opportunity to provide feedback on MISO’s RA Risk Metrics and Criteria.

The EOCs generally support the idea of studying alternative resource adequacy risk criteria but do not believe that the current proposed timeline of beginning and completing the initial analysis in 2024 provides enough time to appropriately study this issue. Moreover, the EOCs do not believe that MISO should implement any new resource adequacy criteria before the existing filed and active resource adequacy tariff changes have been implemented, such as the Reliability Based Demand Curve (RBDC) and the resource accreditation changes. For these reasons, the EOCs are not opposed to MISO studying this topic during the 2025 calendar year but do not support MISO making any FERC filing on this issue during 2025.  Delaying any FERC filing to implement these changes will afford time to more fully evaluate and develop the new risk criteria with stakeholder input – and also allow the results of previous market design changes to be known (and any lessons learned) before further changes are made.

If MISO places this issue on the management plan, the EOCs have the following feedback:

• In addition to LOLE modeling, the analysis needs to provide a comprehensive view as to how adopting new RA risk criteria would impact future Planning Resource Auction clearing prices and the quantity of resources cleared accounting for the RBDC.
• MISO must maintain a “Do Nothing” course of action as an option and as a potential result of this analysis. For example, if MISO’s analysis shows that the additional capacity clearing in the PRA because of the RBDC has the effect of sufficiently lowering Expected Unserved Energy (EUE) then it is likely reasonable to conclude that additional RA Risk Criteria are not needed. Additionally, if stakeholders believe that the cost of additional capacity needed to lower system EUE is too expensive to justify the improvement in system reliability, then MISO should not move forward with adopting additional RA Risk Criteria.
• MISO should work with other RTOs in studying this topic. Given that MISO is part of the broader Eastern Interconnect and that capacity is portable, it is reasonable for all RTOs in the Eastern Interconnect to adopt the same (or similar) resource adequacy criteria targets. Moreover, studying this issue in partnership with other RTOs will provide greater access to data and should result in a more robust analysis.

If MISO does not place this issue on the management plan, the EOCs support MISO including additional resource adequacy metrics into ongoing MISO products. For example, instead of reporting only LOLE data in the annual MISO LOLE Study, MISO could begin including in those study results EUE and Loss of Load Hour (LOLH) metrics as well.

Echoing previous comments on RA construct changes, we ask MISO to provide as much leading information as possible on potential future markets and obligations that this investigation is likely to recommend. It is imperative that we begin to test and plan for these RA evolutions in our ongoing resource planning efforts, as it we are making long-term investment decisions today which are difficult to unwind down the road.

Alliant Energy is open to RASC discussion of issue and management plan acceptance, but we encourage MISO not to rush the process. Moreover, MISO should consider reaction time needed to respond to construct changes in LSE long-term planning processes. MISO is already proposing significant changes to the 2028 Planning Year, and it seems the resource adequacy staff is already very busy with those efforts (as well as the annual resource auction).

Clean Grid Alliance appreciates this opportunity for stakeholder feedback.  

MISO should give stakeholders a meaningful role in determining, developing, and using the results of MISO's research agenda with regard to possible changes in the resource adequacy construct, especially fundamental changes involving metrics used to define reliability or resource adequacy.  The implications of any such changes for the seasonal Planning Resource Auction could be profound.  They also could be superfluous or even counter-productive if the outcomes relevant for given metrics could be more efficiently achieved by incentives created in the Energy and Operating Reserves and other Ancillary Services markets.  In those and other ways, the opportunity costs of MISO's initial research agenda could be significant.  Thus MISO should collaborate with stakeholders before beginning, while conducting, and when interpreting the results of any significant resource adequacy research.

I am happy to discuss.

David Sapper

dsapper@cleangridalliance.org

WPPI agrees that this is a potentially important issue, and we are open to discussing it.  We find MISO’s proposed timeline overly aggressive, however.  We expect we would need more time than contemplated by MISO to prepare for MISO’s detailed presentations, consider the issues, discuss with other stakeholders and provide meaningful feedback to MISO.  We believe November 6 is likely to be too early to develop a final recommendation and recommend delaying this until 2025.  We also recommend that MISO post materials for the workshop as early as possible, preferably 2 weeks ahead of time.

Minnesota Power appreciates the opportunity to provide stakeholder feedback in regard to the Reliability risk metrics.  We agree with the other stakeholders indicating that this is not the time to pursue the issue of expanding reliability metrics. 

We continue to have many concerns on deeper details on a number of issues on planned exempt outages and other SAC implementation issues.  The allocation of PRMR to LSEs for the DLOL is another significant issue that isn't getting adequate attention.  

System reliability will not be definitively continued or increased by having the right metric or set of metrics in a LOLE model.  Reliability will be understood and maintained by having adequate analysis showing the amount of capacity resources needed by attribute on a system-wide basis.  LSE and State directed planning processes will have a much more informed process of what we are needing.  If we wanted to take the DLOL PRMR analysis showing how the LSE allocation process take place, this analysis could also be used to derive an allocation of the quantified attribute analysis, so the allocation of the amount of resource attribute could be assigned to the LSE.  Once that is shown, it provides the indication how fast the resource retirements can occur and what amount of resource by type.  States will be able to have an indication of what is needed for reliability, and what contributions each LSE should be able to demonstrate that all parties are not simultaneously depending on  "the market,"   The current path we are on is not able to show the path to maintaining a reliable system.  

The OMS Resources Work Group (RWG) provides this feedback to MISO in response to its new issue submission regarding the exploration of alternative resource adequacy metrics. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors. 

States are the entities responsible for resource adequacy in the MISO footprint. OMS will be in touch with MISO leadership on this matter, timeline, and process.

OMS seeks to ensure alignment with our 2024 priority on this topic, "Ensure any modifications to reliability requirements align with state and local planning processes and retail tariffs and consider inclusion of additional resource adequacy risk metrics."