RSC: Proposed BPM update for Operations Modeling Data Submittals (20240530)

I found some of the wording to be confusing, so I am attaching my redline suggestions for BPM-010.

I have read through the proposed changes.

They seem reasonable to me.

Thank you.

RSC: Proposed BPM update for Operations Modeling Data Submittals (20240530)

At ATC we understand the need to provide model updates in a timely manner to support reliable model development and testing.  The current MISO processes call for submittal of modeling information up to 6 months in advance of the in-service date for new facilities or the modification of existing facilities.  Within ATC, the grid is evolving faster than ever, and we expect our neighbors are experiencing the same. Expecting your members to have complete knowledge of specifics that will happen in the next 6 months seems like an unrealistic expectation and will be very difficult to achieve. Supply chain issues, specialized manpower, regulatory hurdles, project prioritization, and system emergencies all require careful planning from the TO/MP when setting the expectation to model so far in advance. However, these are all out of our direct control.

When changes in schedules or plans occur, ATC will provide information to MISO as soon as it is available for the work we know about before the deadlines on the 8^th of the month.  If we elect to submit a late project, it is because we have already done the analysis and understand the negative impact not making the change will have on your models, not because we have been careless with the timeline due dates.  Requiring us to justify that and get management signoff is additional work that provides little or no value to ATC or to MISO.

If MISO is having issues with chronically late submittals from specific members, this seems like a good approach to use with them to correct those issues.  Inflicting this overhead on all members is unduly burdening those companies who are already following your procedure to the best of their ability.

One of the selling points when MISO started the transition to MAGE was that it would allow you to pursue more frequent and easier model updates.  Increasing the frequency of your model updates would shorten the time frame where we had to have knowledge of all changes and make it less likely that late submittals would occur.  If you are not looking at more frequent model updates, we recommend you revisit that option which will help address the issue at hand.

ATC is striving to support grid reliability and the MISO Markets in the most efficient manner. ATC wants MISO to understand the modeling expectations are not aligned with the current reality we all work under, so there should be some level of flexibility allowed to accommodate changes as they occur.  As the grid is evolving more and faster than ever, this is extremely important. Requiring earlier submittals and additional overheads when TOPs/MPs submit late doesn’t seem like the best long-term approach to align with the speed and magnitude needed to make this process successful.

Jim Kleitsch - Principal System Operations Engineer - ATC

At the May 30, 2024 Reliability Subcommittee meeting, MISO proposed changes to Business Practices Manual 10 – Network and Commercial Model to address late model change submissions. Based on WPPI’s review, it seems it would be helpful to clarify the new, formal process involves submitting both (1) a form (providing information described by the proposed edits) approved by a “supervisor” and (2) the change in Model Manager. Also, it would seem helpful to provide more definition around “supervisor” (e.g., the supervisor or higher of the person submitting the change in Model Manager).

DTE appreciates the feedback opportunity. 

1. Overall, DTE believes employing this process update for late submissions is logical.  DTE has concerns with treating corrections with the same scrutiny; especially if the initial submission was on time.
2. This process change is being discussed May 30 at the MSC but the first instance of formal review of late changes is going into effect for the September 2024 Model build cycle which starts June 1^st, 2024. 
   1. Is that really enough time to transition into this new construct?
   2. It would make more sense to introduce this change for the December 2024 Model build cycle which is in September? (In the event MISO receives a heavy volume of comments in opposition of this update.)
   3. It is fairly common for corrections and rework to occur with model updates (especially Slice of System); the MISO Modeling Team generally do not inform MPs of the need for correction until after the submission deadline.  So by the new process all corrections, no matter how minor, would require this formal approval?  That would take unnecessary time.
   4. MISO will provide a form to fill out starting with the September 2024 model build cycle” (slide 8)

1. 1. 1. How will this form be provided? Where can it be found?
      2. Is there a preview of the form?
      3. If everything related to modeling is handled in MMM, why introduce a separate form?  Why have it submitted via the MISO website (long-term) and not via MMM?
      4. Will the form need to also be attached to the MCR in question?

5.DTE is assuming that the secured signatory process of documents like a Section XI is not included in this new proposal? In DTE's experience, those are not generally reviewed/completed prior to the submission deadline

6.What is the ultimate advantage of introducing the formal review?   DTE can understand having a standard way of approaching late model changes to ensure none are overlooked but it seems like more steps are being forced fit into an already tiny correction window of 2 weeks