Stakeholders continue to criticize MISO’s proposal to create seasonal capacity auctions and resource accreditation, saying it is too hasty and not rationalized, and warn they may pursue a more formal channel to vent their frustrations.
Those participating in MISO’s Resource Adequacy Subcommittee might soon memorialize complaints with a formal stakeholder vote. They’re currently completing email ballots on a motion to delay resource adequacy changes by a year until the 2024/25 planning year and to extend debate until at least the second quarter of 2022.
The MISO Coalition of Utilities with the Obligation to Serve introduced the measure during RASC’s meeting Sept. 1. MISO considers stakeholder votes as advisory in nature.
The motion also asks the grid operator to augment its proposal with three add-ons:
- a “transparent” and “robust” analysis to justify major changes to the resource adequacy construct;
- histograms and calculations of seasonal long- and short-capacity positions by local resource zone so that members can estimate the seasonal framework’s impacts on their fleets; and
- a way for the RTO to “recognize prudently planned outages’ contribution to resource adequacy.”
“Prudently planned outages actually increase reliability,” Big Rivers Electric’s Marlene Parsley said during the RASC meeting.
Parsley also said MISO was tweaking the filing at the “11th hour” and said its proposal “continues to evolve late in the stakeholder process.”
The grid operator has said it will file a proposal before October with FERC to create four independent seasonal auctions with distinct reserve margin requirements and a tougher seasonal capacity accreditation. The proposal will focus on a unit’s availability over the past three years during the riskiest 3% of hours in a season to develop individual accreditation values for planning resources. MISO defines risky hours as those with either a maximum generation event or tight margin hours. (See Discord Persists over MISO Seasonal Capacity Accreditation.)
MISO said the changes are necessary to reverse a trend of shrinking reserves and a spate of maximum generation emergencies since 2016.
But the utilities group said, “MISO is seeking to fundamentally re-engineer nearly every aspect of its resource adequacy construct in a way that no other U.S. RTO has ever undertaken.”
It also said the RTO should prove that its “quasi-random set of tight margin hours has any predictive correlation with future performance during a different quasi-random set of tight margin hours.” Stakeholders have said MISO basing accreditation on unit availability during preselected risky hours throughout a season makes accreditation a volatile and hard-to-predict process.
Customized Energy Solutions’ Ted Kuhn said MISO effectively ignored stakeholders’ request to first try seasonal capacity auctions before tinkering with capacity accreditation values.
“Stakeholders are finding they have a proposal in front of them that’s half-baked,” he said.
Madison Gas and Electric’s Megan Wisersky said the grid operator’s current proposal was “incoherent” and agreed MISO would be better served with a staged approach.
During a Wednesday workshop, some stakeholders said the proposal appeared to still be in the design phase, rather than a finalized plan days from being filed at FERC.
Stakeholders questioned the seasonal outage rules that limit outages to a cumulative 30 days in a season before resources must replace the capacity they’ve signed up to provide.
Some said the limit in duration might encourage some unit owners to take shorter planned outages every year instead of risking replacement capacity requirements during more comprehensive maintenance outages once every two or three years.
“I think MISO needs to think more seriously about this,” Kuhn said.
MISO staff promised that its outage coordinators will monitor patterns across units in outage behavior and propose new rules as necessary.
