Stakeholders asked for more time during MISO’s final scheduled meeting to design a four-season capacity auction, seasonal reliability targets, and an availability-based accreditation.

Speaking during Wednesday’s Resource Adequacy Subcommittee teleconference, staff’s Scott Wright said a special stakeholder workshop in September and a RASC meeting that same month will be dedicated to drafting tariff language.

MISO says it will file a proposal with FERC at the end of September to create four independent seasonal auctions and tougher accreditation metrics. (See Discord Persists over MISO Seasonal Capacity Accreditation.)

Wright pledged an additional stakeholder workshop Aug. 19 to review the proposal.

Stakeholders said MISO’s filing timeline remains too aggressive for such a big change.

“This is completely railroaded and rammed down everyone’s throat, to be frank. We need more time on this,” Power System Engineering’s Tom Butz said.

WPPI Energy’s Steve Leovy said he was doubtful that stakeholders could gain a full understanding of the new auction design before MISO files it. “We have such a complicated framework here with accreditation, resource-adequacy hours, outage coordination and replacement requirements,” he said.

“I’m having a hard time understanding how all the pieces fit together,” said Clean Grid Alliance’s Natalie McIntire.

“We support delaying the filing so we can get it right instead of just getting it in,” the Coalition of Midwest Power Producers’ Travis Stewart said.

“All of us need to go back with this to our operators and plant operators, the people who this filing is going to affect,” WEC Energy Group’s Chris Plante said.

MISO Director of Market Design Kevin Vannoy said the grid operator’s design values resources’ contribution to reliability.

“Since 2016, roughly 75% of our emergencies have taken place outside of summer,” he said. “It’s key that we start addressing resource availability and capacity requirements outside of summer … We want to have confidence that the resources that we’re counting on are made available to us.”

MISO has been meeting with members to discuss their planning resources’ accreditation values. Its new accreditation will assign an 80% weight on a planning resource’s availability during the riskiest 3% of hours in capacity accreditation, while non-risky hours will carry the remaining 20% weight.

The RTO said if it can’t detect enough risky hours during a season for accreditation, it will supplement with a resource’s average availability during risky hours outside of the season.

The accreditation design remains a point of contention between MISO and stakeholders.

At the July 20 Entergy Regional State Committee, MISO South commissioners asked that staff consider a 60-40 weighting split for risky hours.

Entergy’s Wyatt Ellertson said his utility still doesn’t understand how MISO arrived at an 80% weight assignment. He said generation owners are always trying their best to meet demand during tight margins.

Texas Public Utility Commission economist Werner Roth said MISO sold a seasonal construct on the basis that it would better pinpoint risk in seasons. He said the plan to draw on performance during hours outside of the season for accreditation was disappointing and wouldn’t paint a true picture of seasonal risk.

MISO Independent Market Monitor David Patton criticized the RTO’s 24-hour grace period for start-up times in its accreditation as too lenient and said it should allow for only a four-hour response lead time.

“It creates the illusion of a large margin in a season,” Patton told MISO staff. “It provides too much credit to resources that are not contributing to reliability.”

Patton said that as MISO gains more renewable resources, it will be less likely to anticipate emergency conditions and could be caught off-guard with the generous lead times.

“As the system evolves, we’re going to be in a situation where the peaks are not necessarily hours we’re going to see coming 24 hours in advance. It’s like we’re trying to hang on to the old world with this 24-hour lead-time provision,” he said. “At some time, we’re going to have to acknowledge that we need a more flexible portfolio.”

MISO has also proposed that planning resource outages last no longer than 30 days during a 90-day season. Unit owners planning outages longer than a month will be disqualified from participating in a seasonal auction. If a cleared resource foresees an outage lasting longer than 30 days before the season starts, planning resources owners must procure replacement capacity for every day beyond the 30-day threshold.

Staff isn’t currently proposing any financial penalties for failure to replace capacity due to outages. The planning resources will, however, face hits to their accreditation if they fail to secure capacity replacements.

MISO will also use an existing rule that planning resource owners must notify it 20 days in advance of planned outages.

Vannoy said staff will publish the risky resource hours that accreditation will rely on months ahead of time so that generation owners can plan their outages.

Ellertson asked MISO to show generation owners the calculations behind individual resources’ accreditations so owners can see how resource hours interact with planned and forced outages.

“It’s kind of a black box to how MISO arrived at those numbers,” Ellertson said.

Minimum Capacity Requirement

MISO’s sweeping proposal also contains a new requirement that load-serving entities must demonstrate they’ve secured at least 50% of their capacity obligations prior to a season before a capacity auction.

Patton has said he disagrees with MISO’s minimum capacity requirement and has called it a solution in search of a problem that doesn’t exist. The IMM also said auction prices should motivate an adequate capacity supply.

MISO adviser Stuart Hansen said a minimum capacity requirement is a natural extension of staff’s assumption that LSEs are actively planning adequate supply to cover their obligations and not simply rely on the voluntary capacity market.

“We don’t want this to become an issue,” Hansen said.

“This is MISO throwing up its hands and saying, ‘We don’t trust the markets,’” Patton said. “It sounds very parental, to be honest …  If capacity is available [in the Planning Resource Auction], why isn’t it responsible to buy it? If you’re saying you don’t want people to rely [on the auction], you’re basically indicting your own market.”

Wright pointed out that LSEs have several checks and balances from their state authorities. He said adding one small MISO obligation wouldn’t be a burden.

“If it’s parental, so be it,” Wright said.

Patton promised to protest the filing if MISO includes the minimum capacity requirement. “If you put a flawed idea into your filing, you risk the whole thing getting thrown out,” he said.