By Amanda Durish Cook

CARMEL, Ind. — MISO is preparing to make two resource adequacy filings with FERC aimed at making its capacity resources more readily available.

The RTO last week promised two filings in late April that would ensure that resources procure transmission deliverability to their full installed capacity levels before receiving full capacity credits and shave the capacity credits of some load-modifying resources (LMRs). If approved, both will impact the 2021/22 Planning Resource Auction.

LMR Accreditation

MISO said it will file a proposal to establish an LMR’s capacity accreditation as the smaller of either an average of its actual availability over a three-year period or its tested availability. LMRs that can respond more often and with shorter lead times will receive a larger capacity credit, while those that can respond to 10 or more calls in a year will receive full capacity credit. (See MISO Pursues Leaner LMR Accreditation.)

The RTO will also no longer qualify LMRs with lead times greater than six hours as emergency-only resources because they don’t help mitigate emergency events. However, those long-lead LMRs will still be eligible to qualify as capacity resources.

Speaking at the Resource Adequacy Subcommittee’s meeting Wednesday, MISO planning adviser Davey Lopez pointed out that other RTOs require much shorter lead times for their LMRs. PJM requires its emergency resources have anywhere from a 30-minute to two-hour requirement, while NYISO’s LMRs have a two-hour requirement once called upon. CAISO’s reliability demand response resources have an obligation to reach their maximum curtailment within 40 minutes of dispatch instructions.

The RTO also announced this week it would not use the MISO Communications System to evaluate data for accreditations. Stakeholders often criticize the nonpublic site as outdated and difficult to use to update LMR availability.

Nevertheless, stakeholders have said the proposal seems designed to punish LMRs.

Customized Energy Solutions’ Ted Kuhn said he anticipated that the new LMR accreditation could cut capacity supply by as much as 6 GW.

“This is a ‘yank the rug out, blow out the back door, and then cover the back with a tarp and hope everything is OK’ kind of approach,” Kuhn said.

Capacity Deliverability

MISO is also working on a proposal to allocate capacity credits to resources based on their deliverability relative to ICAP levels.

The RTO said it won’t require that planning resources procure full transmission service up to their ICAP levels; however, resources that that are only partially deliverable won’t receive full capacity credits. The RTO said it’s fine if conventional generators opt not to purchase additional transmission service and settle for fewer zonal resource credits.

MISO also plans to file the new condition for full capacity accreditation with FERC in late April.

By December, MISO will work up unforced capacity values for the 2021/22 PRA. By April 2021, it will run the PRA using its new deliverable ICAP policy.

MISO has already said it plans to model intermittent resources using actual historical market injection values, which will reduce some units’ UCAP values and stand to reduce capacity credits. The RTO first developed a possible solution only for its intermittent resources, citing increasing wind curtailments in the footprint. (See “MISO Pushes Back Deliverability Requirements,” MISO RASC Briefs: Oct. 9, 2019.)

MISO Manager of Capacity Market Administration Eric Thoms said Iowa stands to be the most affected by the new deliverability requirement simply because the state contains a lot of wind generation.

The Independent Market Monitor has said that the RTO doesn’t properly account for capacity deliverability because its loss-of-load expectation study assumes all capacity resources are fully deliverable on an ICAP basis. However, the RTO allows resources to demonstrate deliverability only up to UCAP levels, which tend to be about 5 to 10% below full ICAP levels. The Monitor has said MISO should ensure all capacity resources are fully deliverable based on their ICAP.

MISO Preps 2020/21 PRA

At the same RASC meeting, MISO reported that estimated values for the 2020/21 PRA have remained consistent, sticking with an almost 122-GW coincident peak forecast and a nearly 136-GW planning reserve margin requirement. (See Little Change in MISO 2020/21 PRA Assumptions.)

MISO will update preliminary PRA data a final time March 19. The PRA will be conducted April 1 to 14, with the RTO posting prices April 14 and conducting a stakeholder conference call April 15.