CARMEL, Ind. — MISO will reconsider its penalty exemption policy for already submitted generation outages, officials told the Reliability Subcommittee May 2.
Under new outage scheduling rules effective April 1, MISO will exempt from penalties planned outages scheduled 120 days or more in advance. Penalties for outages scheduled 119 days to 14 days in advance occur only when MISO’s maintenance margin tool predicts scant resources to cover operations. Outages scheduled fewer than two weeks in advance are subject to generator accreditation penalties if they don’t alter their outage timeline to move out of MISO-defined periods of capacity concern. The rules also dictate that to receive a penalty exemption, the same unit cannot take multiple outages within a 120-day period. (See FERC OKs MISO Outage Scheduling Rules, DR Testing.)
At the May 2 meeting, stakeholders questioned how MISO might apply accreditation penalties to already planned outages.
Under the new rules, MISO shift operator Trevor Hines said, unit owners must submit a new outage request in order to extend an outage already in progress. For outages yet to begin that require a timeline change, unit owners must submit a change request to MISO, which will reevaluate the requested outage based on maintenance margin supply predictions. The reevaluation would put a unit’s previously approved outage at risk of losing its penalty exemption.
Stakeholders asked why MISO would reevaluate shortened outages, questioning how a truncated outage could possibly impact reliability negatively.
“This seems counterintuitive,” MidAmerican Energy’s Greg Schaefer observed.
Several asked MISO to consider not putting penalty exemptions at risk when a unit is returned early from a planned outage.
Hines said the reevaluation seeks to gauge the impact on other unit outages. He said it’s extremely unlikely that returning early from an outage would cause a dip in capacity projections.
Jeanna Furnish, manager of outage coordination, said the RTO will reevaluate that piece of the new outage rules. She said the focus is only to make sure MISO is aware of early or delayed returns. Hines promised to return to the Reliability Subcommittee with clarifications.
“We do want you to bring your unit back as soon as it’s appropriate and safe to do so. I am hearing that there’s a perception that this is a bad incentive,” Furnish said.
MISO: $2 Million in Penalties for Jan. 30 LMR Underperformance
Less than a quarter of load-modifying resources responding to a late January emergency event performed to MISO standards, the RTO has concluded.
As a result, MISO will issue nearly $2 million in penalties to 26 market participants for underperformance. The RTO also disqualified 21 LMRs for the remainder of the 2018/19 planning year for nonperformance and will assess them $500,000 in penalties. Penalties will be assessed May 31. When LMRs fail to perform, MISO derates the resource proportionally for the rest of the year.
MISO deployed 180 LMRs on Jan. 30; this marked the first time it has called on LMRs in the north and central regions of the footprint. (See MISO: Winter Emergency Another Signal for Grid Ops Change.)
Though the LMRs managed to meet MISO’s scheduling instructions 75% of the time on average through the worst of the cold snap, the RTO said its measurement and verification criteria found widespread under-delivery of demand reduction megawatts. MISO said only 103 of 502 LMRs called on during the event met MISO’s Tariff-defined compliance standards across all hours of the emergency event. LMR performance gradually improved from about 69% of megawatts requested delivered to 97% over the five hours of LMR use.
MISO analyst Scott Thompson said LMR owners should work on making their availability to the RTO more accurate. While LMRs do not have to be available for scheduling instruction outside of the summer months, MISO does require that LMRs communicate their unavailability via the communication system. LMRs can submit availability up to seven days in advance.
“Correct LMR availability is critical to our real-time operations. LMRs need to ensure that availability aligns with their resource capability,” Thompson said.
Thompson also said many LMRs provided more megawatts than MISO requested. He said while the excess was “a good thing,” it also illustrates that LMRs are not providing their most up-to-date capabilities to the RTO. He also said all LMRs at least acknowledged scheduling instructions on Jan. 30.
Thompson also granted that the MISO Communication System — where LMR owners update their availability — “may not be the prettiest tool we have.” The system is currently undergoing an overhaul as part of MISO’s multiyear effort to replace its current market platform with a new cloud-based, modular platform.
MISO has contacted all 26 LMRs owners facing penalties to discuss the event and their penalty amount, Thompson said.
“Everyone was given an opportunity to share and discuss their performance with MISO,” he said.
Customized Energy Solutions’ Ted Kuhn said LMR penalties might need to be reassessed since MISO now requires LMRs to submit year-round availability. (See MISO LMR Capacity Rules Get FERC Approval.) He said the penalties were originally designed to be harsher than penalties for generators because of LMRs’ shorter availability requirements. Now that LMRs must commit to providing availability in all seasons, Kuhn said MISO might consider LMR penalties that look more like generation penalties.
Kuhn also asked if there was a tipping point of how many LMRs MISO can handle in its resource mix. The use of LMRs, which can only be accessed in a declared emergency, has been steadily growing in the footprint over the last few years. RSC Chair Bill SeDoris said the exploration of an LMR saturation point will be added to the committee’s management plan for discussion in the third quarter of this year.
— Amanda Durish Cook
