By Amanda Durish Cook

CARMEL, Ind. — MISO says it may reduce the capacity accreditation of some of its load-modifying resources in an effort to improve resource availability in its footprint.

Speaking at a Resource Adequacy Subcommittee meeting Wednesday, MISO planning adviser Davey Lopez said the RTO is considering basing an LMR’s accreditation on the smaller of either an average of its actual availability over a three-year period or its tested availability. LMRs that can respond more often and with shorter lead times will receive a larger capacity credit, he said.

Lopez noted that LMRs are currently “receiving capacity credit that’s disconnected from what we see in” the MISO Communications System (MCS). He said an LMR with a four-hour lead time that can respond to 20 calls during a planning year currently receives the same capacity credit as an LMR with an eight-hour lead time that can only respond the requisite five times per year. MISO is proposing that better-performing LMRs receive a higher capacity credit while slower LMRs with spottier service receive a percentage based on a still undetermined calculation in a loss-of-load expectation (LOLE) study.

“That’s the gap we’re trying to close here,” Lopez said, reminding stakeholders that the proposal is still a draft.

MISO stakeholders should expect an April filing with FERC to adjust LMR accreditation in some manner, Lopez said.

The changes are proposed as LMRs take an increasing slice of the RTO’s capacity supply. MISO has gone from clearing about 9 GW of LMRs in its Planning Resource Auction in 2017 to almost 12 GW in 2019. Lopez said that since the last PRA in April, LMRs’ daily availability on average is about 4 GW short of what was cleared, according to MCS self-reporting of availability.

Stakeholders: MCS Still Wanting

Multiple stakeholders asked why MISO would rely on MCS data when the stakeholder community has called navigation of the nonpublic MCS site clunky and confusing. They called for the RTO to reinvigorate a shelved effort to improve the MCS for its users. (See MISO to Fix Communications System Shortcomings.)

“This is now the second time you’ve come before us about LMRs. There was a filing last year on LMRs; now there’s going to be a filing this year. If LMRs are such a concern, then this MCS tool needs to get fixed, and the senior management needs to get on board with getting it fixed,” Customized Energy Solutions’ Ted Kuhn said, prompting nods of agreement from several stakeholders. “I continue to find that using MCS data is problematic.”

“I guess my response is that the MCS is our system of record,” Lopez said, adding that it’s undeniable that LMRs aren’t showing up as promised. “We want to give our operators the best information possible during emergencies. And right now, what’s clearing in the PRA is nowhere near what’s showing up in the MCS. … The accreditation should reflect that.” Lopez said LMR availability has become especially important given that MISO now experiences the possibility of an emergency in every month, not just the summer ones.

Lopez said recent analysis shows LMRs’ uneven availability contributes to about a 2-GW increase in the planning reserve margin (PRM) requirement. Removing LMRs from the equation reduces the requirement from 136 GW to 134 GW for the 2020/21 planning year.

Kuhn suggested MISO create a separate class of better-performing LMRs for capacity auction purposes. “An LMR-plus, or something,” he said.

Independent Market Monitor David Patton has recently criticized MISO’s planning studies for still assuming that emergency resources are available to respond even when their long lead times preclude them from doing so. Patton said the problem remains that the RTO must first declare an emergency before calling up LMRs for dispatch.

MISO early last year promised to issue LMRs individualized scheduling instructions before an emergency occurs based on their unique notification times. It has also promised to confirm or withdraw advanced scheduling instructions at least two hours prior to an expected emergency event.

The LMR proposal is part of MISO’s resource availability and need project, a multistage endeavor divided into resource adequacy and market improvements.

While MISO’s Market Subcommittee focuses on possible market changes, including emergency pricing edits and providing market information in advance of the day-ahead market, the RASC is dissecting a possible seasonal PRA and new LOLE modeling and capacity resource accreditation. (See MISO Weighs Seasonal Capacity, Accreditation Plan.)

Lopez said the possibility of a seasonal auction is still on the table, though it will be discussed at later RASC meetings.

LOLE Refinements

MISO also used Wednesday’s meeting to unveil a proposal to model more real-world conditions in its annual LOLE study, encompassing more generation outage risk and intermittent resource behavior.

Lopez said MISO wants to use “more appropriate” wind generation and intermittent resource output levels that are based on unforced capacity values in non-summer months.

MISO is also proposing to combine 30 load shapes to create a more realistic outage pattern for a typical weather year and use the actual availability of its demand response resources to predict the likelihood that they’ll respond.

“If we plug these changes into the 2020 PRM model, it’s approximately a 1% increase to the PRM,” Lopez said.