By Amanda Durish Cook

CARMEL, Ind. — Stakeholders are urging MISO to slow down on bigger ideas to address its disjointed resource availability and need (RAN) until it can measure the effects of three smaller related filings pending before FERC.

For the remainder of this year and through 2020, MISO’s Market Subcommittee and Resource Adequacy Subcommittee will discuss long-term methods of shoring up resource availability as reserve margins decline.

Speaking at a Feb. 5 RASC meeting, MISO Director of Resource Adequacy Coordination Laura Rauch said most of the discussions will take place independently, though the RTO may schedule joint MSC and RASC meetings on the topic.

MISO recently filed new near-term rules for load-modifying resources (LMRs) and planned outages to buy time for more comprehensive solutions. Up to the filings, stakeholders had also urged a slower approach to developing those rules. (See MISO Files New Planned Outage Rules.)

Nearly a month later, MISO is ready to take on the broader proposals, which may include changes to the annual capacity auction, loss-of-load expectation study and capacity accreditations. It said the second and third phases of the project will address “gaps in the efficient conversion of committed capacity to energy.”

So far, a number of stakeholders maintain that MISO’s timeline on the multifaceted project is too aggressive, with some saying that it should evaluate the effects of its LMR and outage filings before it moves on to long-term remedies.

“A lot of comments focused on that we’re moving too fast; the two phases are being rushed. … We do plan on working through the stakeholder process over the next few months to make sure that any solution is vetted,” MISO planning adviser Davey Lopez told stakeholders at a Feb. 6 RASC meeting.

MISO Executive Director of Market Development Jeff Bladen said the RTO is starting conversations now with an eye on recommending long-term solutions within a year and a half.

“This is a marathon, not a sprint,” Bladen said.

“At what point does MISO declare victory? Is there some point where there’s enough of a buffer that MISO stops making changes?” asked Bill Booth, consultant to the Mississippi Public Service Commission, adding, “We’re moving at warp speed.”

Rauch said the RTO will continue determining whether improvements are enough to maintain reliability by gauging whether increasingly frequent maximum generation events are more accurately predicted and managed.

“The goal is not to eliminate all emergency conditions. That’s part of our normal operations,” Rauch added.

Lopez said MISO plans to analyze the impacts of the LMR and outage filings and compare upcoming capacity auction results with prior year auctions before it proposes any changes to capacity accreditation. MISO has said it will investigate adjusting capacity accreditation “based on the ability to resolve resource risk.”

Seasonal LOLE?

Lopez asked for stakeholders’ written feedback on the usefulness of a seasonal capacity construct, an idea long pondered in MISO. The RTO last proposed a two-season capacity auction in mid-2016 before talks stalled, and stakeholder appetite for a revised proposal resurfaced last year.

Some stakeholders said MISO’s loss-of-load expectation (LOLE) study could use improvement if the RTO moves to a capacity auction structure based on either two or four seasons.

Multiple stakeholders said MISO should first examine possible technical changes to the LOLE study — which is based on an annual summer peak — in light of moving to a one-day-in-10-year reliability standard based on seasons.

“Without basic technical LOLE work, I don’t know if we can start the discussion. … I think that needs to be upfront before we can even start on the policy of this,” Minnesota Public Utilities Commission staff member Hwikwon Ham said. “Software can spit out any number you want to. That doesn’t mean you’re getting the right result on your statistical theory.”

Rauch said MISO would have to conduct research to determine which LOLE inputs and calculations would be appropriate.

A seasonal construct also raises the question of whether interconnection service should be divided by seasonal availability, Lopez said. He also said stakeholders should consider whether they prefer a single annual action with seasonal offers or multiple separate seasonal auctions.

Independent Market Monitor staff Michael Chiasson said a seasonal auction would satisfy some IMM recommendations, particularly its longstanding recommendation that resources be accredited according to their ability to deliver across varying conditions.

A day later at a Feb. 7 Market Subcommittee meeting, Bladen insisted that MISO doesn’t currently have a load forecasting problem, but an uncertain resource availability problem.

“It’s not the uncertainty itself that’s increasing. It’s the nominal impact of that uncertainty that’s increasing,” Bladen said.

Beyond LMRs

Stakeholders also asked if MISO will begin focusing on other resources besides LMRs, inquiring about possible changes to the modeling or accreditation of baseload or intermittent resources.

MISO staff said a wide array of changes are on the table and that the RTO might also consider incentives for LMRs with shorter lead times.

“We’re going to let the advice from this committee guide us,” Bladen told the RASC. He later added that while stakeholders and MISO may not have the time to examine upwards of 30 solutions, there’s still a “veritable menu” of options.

MISO said stakeholders may want the RTO to further incentivize economic demand response and improve its scarcity price formation. It also said it could reduce capacity accreditation for long-lead resources.

MISO plans to continue the RAN discussion at the March RASC and MSC meetings.