CARMEL, Ind. — MISO said it likely will split load-modifying resource participation into two options in an effort to line up their true contributions with accreditation.
MISO’s Joshua Schabla said the RTO is considering “flexible and rigid” capacity-only demand response participation options for LMRs.
Stakeholders learned at a July 10 Resource Adequacy Subcommittee (RASC) that MISO wants to introduce a category for LMRs that take longer than 30 minutes to react. Those LMRs would be tasked with responding to the first step of a NERC Energy Emergency Alert and their accreditation would be based on response times and availability.
The second class of LMRs would commit to be available for deployment in 30 minutes or less for the second step of a NERC Energy Emergency Alert (EEA 2). Those resources would have to be able to respond to an unlimited number of EEA 2 events. Currently, LMRs must respond up to five times apiece in summer and winter months and up three times in spring and fall, and MISO must reach an EEA 2 to access LMRs.
Under the pair of options, LMRs’ must-offer requirement would kick in during MISO’s capacity advisories or emergency declaration hours. The first set of LMRs would submit their real-time availability through MISO’s market user interface for MISO dispatch; the second set of LMRs would continue to communicate availability through MISO’s demand-side response interface for scheduling instructions.
MISO said it may rename one of the two categories to something other than LMR. The grid operator warned stakeholders in May that it needs to reassess its LMR concept and requirements. (See MISO Says Risk Driving It to LMR Reorganization, Stronger Requirements.)
MISO first proposed in spring that all LMRs should be available in 30 minutes or less, with those unable to meet those response times relegated to participating as demand response resources. It’s since walked back that proposal after stakeholder criticism. Multiple stakeholders argued that the 30-minute minimum was too drastic and that MISO was trying to treat LMRs — with characteristics that vary wildly — the same.
Schabla said one lenient and one rigorous LMR class should allow most of MISO’s 12 GW of LMRs to continue participation in MISO with a more honest stock of their abilities.
“We want to be mindful — compassionate, frankly — about what these resources are capable of,” he said. “There still is value to resources that take longer to respond.”
MISO hasn’t yet landed on a maximum response time it will accept from the slower class of LMRs. Currently, MISO LMRs have a requirement to be ready in six hours or less.
Schabla said the type of participation LMRs opt for and how quickly they can respond will set the value of their capacity accreditation, with LMRs participating in the second category naturally receiving the most capacity value. However, he said MISO has yet to work out “firm numbers” behind accreditation calculations and will release more detail on the methodology in August.
Bill Booth, consultant to the Mississippi Public Service Commission, asked if MISO had to upend its current LMR construct at all and if it could instead simply create a “super LMR” category for the fastest resources.
Schabla said the second participation option can be thought of as the “super LMR.”
Sustainable FERC Project’s Natalie McIntire thanked MISO for incorporating nuance into LMR accreditation and allowing resources the chance to help the system based on their ability.
Other stakeholders weren’t as convinced.
Executive Director of Market Innovation Zak Joundi asked stakeholders to be open-minded about MISO’s proposal, though they might not like it. He said MISO is trying to capture the value of LMRs based on how they perform.
“We are trying to better utilize this asset class. Period,” Joundi said. He said when the LMR class was created, MISO had a large surplus and virtually never used them. Now, Joundi said an increasingly intermittent fleet and volatile weather means MISO and stakeholders should rethink LMRs as something MISO needs to tap into more often.
“Going forward this is 12 GW that we are likely to leverage, and we need to have the visibility and the confidence that we can utilize them,” Joundi said.
MISO has said its historical data shows actual LMR availability always is lower when compared to the cleared LMR capacity in Planning Resource Auctions. It also has said some LMRs clear auctions without ever making themselves available.
WEC Energy Group’s Chris Plante said his control room operators currently “don’t have a full grasp of what they’re supposed to be reporting and when.” He said MISO isn’t clear about what it expects of LMRs, and it should address that first before reinventing LMR participation.
Plante called MISO’s proposal a “complete divergence of what LMRs have been.”
Joundi reminded stakeholders the LMR accreditation isn’t set to go live until the 2028/29 planning year. He said MISO is working in parallel to be clearer about what it expects of its LMRs.
“MISO seems to be proposing solutions before it understands what the problems really are. That’s unfortunate,” WPPI Energy’s Todd Komplin said.
Komplin introduced a motion and vote in the RASC urging MISO to better investigate the gulf it reports between LMRs’ reported availability and the capacity LMRs clear in auctions. He also asked the RTO to investigate why its control room operators are “effectively using LMRs to address capacity emergencies.”
MISO market participants will vote via email on the RASC motion over the next week.
Komplin said MISO is not explaining why a six-hour lead time on LMRs no longer is sufficient and why it needs LMRs readied in as little as 30 minutes.
Joundi said the motion likely would result in MISO examining what it can do to support LMR contribution. But he qualified that research would occur simultaneously alongside the new participation and accreditation proposal for LMRs.
