By Amanda Durish Cook

CARMEL, Ind. — MISO leadership has not yet decided on how it can improve resource availability, though it is evaluating several possible remedies, the RTO told stakeholders last week.

MISO Executive Director of Market Development Jeff Bladen told an Oct. 4 Reliability Subcommittee that the RTO will return in November with a narrowed list of short-term solutions for review with stakeholders. MISO said it will work with its Steering Committee to assign longer-term recommendations to the RTO’s larger stakeholder groups for further development.

The RTO published a white paper last month focusing on four areas: improving its outage planning; studying characteristics of different resources to see how it can best incentivize them to perform; re-examining resource accreditation in the Planning Resource Auction; and reassessing what availability should be required of resources — especially load-modifying resources (LMRs). (See MISO Moving to Combat Shifting Resource Availability.)

Outage Control

Lately, MISO has been deliberating with stakeholders over whether it should ask FERC for more authority over outage scheduling to better manage reserves. (See Advisory Committee Divided on MISO Outage Authority.) Stakeholders generally agreed last month that MISO should keep the status quo while it works on process improvements.

Some stakeholders said MISO’s challenges may resolve themselves as large transmission buildout from its 2011 multi-value project portfolio begins to come online.

“So maybe it’s a bit of a wait-and-see as the processes we’ve been working on for years begin to bear some fruit,” Bladen said.

“There’s a cyclical nature to this discussion,” Minnesota Public Utilities Commission staff member Hwikwon Ham commented. He said he remembered similar discussions on reserve shortages in the industry around 2005 and 2006.

“This is not a new problem; we can handle it,” Ham said.

Bladen said MISO could require a minimum notice time for market participants taking planned outages. If owners cannot meet the requirement, their outages may be counted as forced outages in their resource’s capacity accreditation. In the long term, MISO said it might consider establishing an outage rights market like the financial transmission rights market that already exists.

MISO reports that about 70% of planned outages during peak months are scheduled with less than a week of notice, based on a three-year average.

“This is surprisingly high,” Bladen said. “There are several planned outages taken very, very close to the operating time frame. Maybe we should put a finer point on what the NERC standard for planning ‘well in advance’ in the MISO context will be.”

Bladen also said MISO could improve the specificity of data it provides to market participants on its nonpublic Maintenance Margin tool, which supplies market participants with projected capacity availability margins to assist them in selecting outage dates.

But MISO’s Independent Market Monitor criticized the Maintenance Margin as clunky, saying market participants are scheduling outages with vague information. Monitor David Patton said the Maintenance Margin information is “high-level and does not convey coincidental transmission outages or generator-specific details that may otherwise impact participants’ planning decisions.”

Historical, not Optimized

Bladen said MISO may begin using historical outage data to inform its planning reserve margin. Such a change could cause an increase to the planning reserve margin, he said.

“We currently anticipate in our planning reserve margin that outages are optimally coordinated. … We may need to plan for outages that are less optimally coordinated,” Bladen said.

Seasonal Auction

However, Patton said a four-season capacity auction with distinct seasonal availabilities assigned to resources would be “far simpler” than adjusting MISO’s existing outage planning.

“The megawatts that are available are the megawatts that matter, no matter why they’re available,” Patton said. “Our [seasonal] deratings are as big as our outages, and many of those go unreported.”

Patton said a four-season capacity auction is “one of the only” possible solutions MISO could explore to better align resource availability with energy needs. The RTO’s current capacity construct socializes the costs of outages and derates by raising capacity procurements, he said.

LMRs

For MISO’s LMRs, stakeholders and the Monitor suggested implementing lead time thresholds.

Bladen said stakeholders suggested MISO reduce capacity accreditation for long-lead resources and incentivize shorter lead time LMRs. Some said MISO should implement a cutoff on response time for a unit to be considered an LMR.

“We have a gamut of lead times in MISO; some are very long leads, some are medium leads and some are short response time. And we don’t think about those as different capacity values,” Bladen said.

MISO should only allow full capacity accreditation to emergency-only resources that can be ready for dispatch within one to two hours and are available beyond the summer season, Patton said. Currently, MISO’s LMRs do not have an obligation to respond to emergencies outside of the summer months.

“Do we have access to the planning resources we procured when we need them … and if not, why don’t we?” Patton asked stakeholders.

Planning studies of LMRs “don’t look anything like” the real-time response of LMRs during emergencies, Patton said. He also said some emergency-only resources’ long lead times render them “essentially unavailable in an emergency” because operators typically don’t see shortages more than a few hours in advance.

“I don’t have anything against LMRs … but if they don’t meet the needs of the system when we procure them in the capacity auction, then we shouldn’t pretend that they do,” Patton said.

Some stakeholders pointed out that MISO can call on LMRs only after it declares emergency conditions. Customized Energy Solutions’ Ted Kuhn said the RTO should consider sending notification to LMRs when emergency conditions are likely but haven’t yet emerged.

“You should be able to notify them that they might be needed, and earlier in the process,” Kuhn said.

MISO’s white paper suggests reordering the steps in its emergency declaration process as a potential solution.

Century Aluminum’s Brian Helms said MISO’s participant communication system should include more information to allow LMRs to decide when to reduce load for either economic reasons or as “the last stop before load shedding.” He also said MISO’s communication system is difficult for owners to navigate.

“Whoever created that, you didn’t get your money’s worth,” Helms said.

“You don’t know what we spent on it,” Bladen responded jokingly.

Reliability Subcommittee Vice Chair Ray McCausland reminded MISO that LMRs were once called “interruptibles.”

“And boy, they complained when you used them,” he said, warning that frequent deployment of LMRs will discourage loads from volunteering to provide the service.

Bladen agreed that MISO’s frequency of LMR use is a delicate balance. He encouraged stakeholders to send in more written suggestions on outage planning, LMR rules and a seasonal capacity auction.

He also stressed that any upcoming recommendations would be technology-agnostic in nature.

“Any technology that can provide solutions will have a shot,” he said.