In the November 29, 2022, meeting of the Planning Advisory Committee (PAC), MISO presented Futures F2A expansion results for stakeholder review and feedback.
Comments are due by December 16.
Entergy Feedback to PAC on F2A Expansion Results
The following feedback is offered by the Entergy Operating Companies ("EOCs")[1] in response to MISO’s request in the November 29, 2022 meeting of the Planning Advisory Committee (PAC) for stakeholders to provide review and feedback of the F2A expansion results:
MISO request for stakeholder review and feedback of the F2A expansion results
The EOCs thank MISO for the opportunity to review and provide feedback on the draft resource expansion for Future 2A. Future 2A is expected to be the focus of the LRTP Tranche 2 portfolio and potentially the LRTP Tranche 3 portfolio. Given the significance of Future 2A, understanding the resource fleet enabled through LRTP transmission projects is critical to support for the transmission projects.
The EOCs have several questions regarding the development of the resource expansion. Can you help our understanding of the process that resulted in the resource expansion by answering the following questions:
The EOCs plan to provide detailed comments on the retirements and RRF units when the resource siting documents are provided in January. Reasonable siting assumptions are critical to development of least-regret transmission projects. We encourage MISO to provide as much time as possible to the siting review.
[1] The Entergy Operating Companies are Entergy Arkansas, LLC, Entergy Louisiana, LLC, Entergy Mississippi, LLC, Entergy New Orleans, LLC, and Entergy Texas, Inc.
MISO PAC Feedback
Big Rivers Electric Corporation
City Water Light & Power (City of Springfield, IL)
Hoosier Energy
Southern Illinois Power Cooperative
PAC Futures 2A Expansion Analysis (20221129)
November 29, 2022
Feedback Provided December 16, 2022
Big Rivers, CWLP, Hoosier Energy, and SIPC (“The Respondents”) thank MISO for this opportunity to provide our perspective on the Futures Refresh information presented at the November 29, 2022 PAC meeting.
We are pleased that MISO is refreshing the Futures because we were concerned about previous statements by MISO that it did not intend to revisit the Futures until after LRTP – which is an untenable position since the LRTP tranche approvals will span many years, and the justification of the largest portfolios of projects in MISO history must not rely on stale data. That being said, we have two primary concerns about the Futures Refresh.
First, we strongly recommend that MISO update the load forecast in any Futures Refresh. It is not appropriate to update the models for fuel prices, announced plans, and Integrated Resource Plans (“IRPs”) without also updating the load forecasts that undergird those IRPs. The load forecasts for the initial set of LRTP Futures were from 2019. If they are not updated soon, the justification for remaining LRTP portfolio tranches will be based on stale load forecast data. Based on the LRTP schedule provided at the June 2022 PAC, note the following dates:
Phase | Load Forecast Date | BOD Approval Expected Date | Resultant Load Forecast Age |
Tranche 1 | 2019 | 2022 Q3 | 3+ years |
Tranche 2 | 2019 | 2023 Q4* | 4+ years |
Tranche 3 | 2019 | 2024 Q4* | 5+ years |
Tranche 4 | 2019 | 2025+* | 6+ years |
*Likely to extend into 2024 Q1 based on comments at December BOD Week.
The LRTP tranches are expected to cost tens of billions of dollars and it is imperative that the justification for capital expenditures of this magnitude rely on the most up-to-date model inputs. Load forecasts are no less important to the model than fuel prices or announced plans.
Hoosier Energy is required to prepare and submit an IRP to the Indiana Utility Regulatory Commission every 3 years and an updated load forecast is a principal component of that IRP. Big Rivers is regulated by the Kentucky Public Service Commission (“KPSC”) and is required to prepare and file an IRP every 3 years. These state regulators would frown upon any plans that relied upon a load forecast that was more than 3 years old. If Big Rivers required approval by the KPSC for a Certificate of Public Convenience & Necessity for any LRTP transmission construction, the KPSC would likely question why MISO would update its models to reflect the most recent IRP but not update them to include the load forecast data that drove the resource acquisition plans in that same IRP. Why take the IRP output without taking the IRP inputs? Why cherry pick some planning inputs and ignore others? These are questions Big Rivers would not be able to answer. We expect other regulated Transmission Owners would be in the same position as Big Rivers and Hoosier Energy in this scenario.
The age of the load forecast puts state regulatory commission approval of LRTP projects at risk, particularly if T2, T3 and/or T4 experience delays in the expected BOD approvals (which seems likely based on informal discussions at BOD Week in December 2022).
Second, if MISO is refreshing the Futures to reflect updates in announced plans and IRPs, those updates should reflect all updates – i.e., not only announced fossil fuel plant retirements or renewal resource targets that indicate an acceleration of the resource mix change, but also any delays to such retirements or extensions to any such renewal resource targets that indicate any deceleration of the resource mix change. The goal is to model the most recent expectations, regardless of whether they accelerate or decelerate rates of change for renewables, electrification, demand response, or other key modeling parameters. Did MISO seek information on and subsequently capture updates in both directions?
The Respondents want the justification of LRTP project portfolios to be based on the most up-to-date models possible. We understand that the effort to update the load forecast is significant, but in our view, it is no less important than the effort to update fuel prices, IRPs, or other announced plans. The cost of these portfolios is far too large to risk justifying them on anything other than the most up-to-date forecasts of all model inputs.
Thank you in advance for considering this feedback.
End Use Sector[1] Comments Regarding Future 2A
Expansion Results
In the November 29, 2022, meeting of the Planning Advisory Committee (PAC), MISO presented Future F2A expansion results for stakeholder review and feedback.
MISO’s LRTP studies have envisioned the use of three scenarios regarding the long term outlook for a 20 year period called “Futures”:
Analysis of Future 1 for the MISO North/Central Subregion was the basis of justifying the $10.4 billion LRTP Tranche 1 portfolio of transmission projects that was approved by the MISO Board of Directors this past summer. MISO has been targeting the analysis of Future 2 for the MISO North/Central Subregion as the basis of the forthcoming LRTP Tranche 2 portfolio of transmission projects. For LRTP Tranche 3, MISO has been targeting the analysis of Future 1 for the MISO South Subregion.
After receiving MISO Board of Director approval for LRTP Tranche 1, MISO decided to pause work on LRTP Tranche 2 in order to update its three Futures with priority being given to updating Future 2, then Future 1 and finally Future 3. MISO has identified the updated Futures shall be designated as Futures 1A, 2A and 3A.
According to MISO’s November 29, 2022 presentation, Future 2A consists of updating input data regarding the following for Future 2 assumptions:
In addition, Future 2 was modified to reflect the recently passed Inflation Reduction Act (IRA) additions and changes to the federal tax credits provisions that apply to renewable generation and battery storage resources. However, MISO has also indicated that it has not reflected all of the provisions of the IRA (e.g., tax credits for carbon capture and sequestration) and it has not updated the Future 2 load forecast.
MISO’s presentation showed that Future 2A expansion result show substantively higher additions and retirements compared to Future 2 and is closer in results to Future 3.[2] Specifically, Future 2A consists of 100 GW of additional installed generation and 35GW of additional retirements compared to Future 2 results. With respect to the additional installed generation, wind and solar generation reaches 30% energy penetration 10 years sooner than Future 2 did. MISO attributes this acceleration in large part due to the incentives included in the Inflation Reduction Act or IRA. The End Use Sector considers these changes to be very substantial and likely over predicting the additions because certain challenges and constraints have not been considered.
While it is reasonable to expect that the trend to acquire renewable generation will increase faster than previously anticipated due in large part to incentives offered in the IRA, it is important to be mindful of key factors that will likely temper the pace with which such generation is actually installed:
There is also on-going concern of a recession, which would further stall investing in new infrastructure. Further, there is inherent uncertainty regarding utility resource plan over 15 years. Generally speaking, there is higher confidence and certainty in the first five years of a utility’s resource plan compared to the latter years of the planning horizon.
For all the forgoing reasons, the End Use Sector believes that MISO should revisit the choice of which Future to use as the primary basis of LRTP Tranche 2. Specifically, we believe it makes more sense to rely on a Future with assumptions that are more realistic with respect to what is actually realizable. In this regard, we believe that Future 1 with updated input assumptions (i.e., Future 1A), including the impacts of the IRA, would be more effective in simulating a more realistic scenario for LRTP Tranche 2 because it takes into account the uncertainty associated with meeting announced goals that are not legislated. Further, since MISO indications have been that Future 1A will also be utilized for developing the Tranche 3 portfolio in MISO South, there will be consistency in utilizing the same Future outlook for MISO’s sub regions. We would also note that given Future 2A looks much closer to Future 3 than Future 2, we expect Future 1A to look much closer to Future 2 than Future 1. Specifically, we expect the generation retirement in Future 1A will be very similar to those in Future 2A and the renewable generation and storage additions closer to those seen in Future 2 than those in Future 1. Given this, we expect significant transmission additions will already be needed to address Future 1A for the MISO North/Central Sub region versus those provided in LRTP Tranche 1 for Future 1. Utilizing Future 2A is now a step too far for LRTP Tranche 2.
The table below shows total GW for the period 2023-2042 by generation type. MISO provided this data showing committed additions, RRF additions and retirements.
We would like MISO to address the following questions:
Thank you for giving us the opportunity to provide feedback. If you have any questions, please do not hesitate to contact any one of us listed below.
Sincerely,
Kavita Maini
PAC End Use Sector Representative
Kavita Maini
KM Energy Consulting, LLC (Consultants to MIC)
(262) 646-3981
Jim Dauphinais
Brubaker & Associates, Inc.
(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)
(636) 898-6725
Ali Al-Jabir
Brubaker & Associates, Inc.
(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)
(361) 994-1767
Kevin Murray
McNees Wallace & Nurick LLC (for CMTC)
(614) 719-2844
Association of Businesses Advocating Tariff Equity (ABATE), Coalition of MISO Transmission Customers (CMTC), Illinois Industrial Energy Consumers (IIEC), Louisiana Energy Users Group (LEUG), Midwest Industrial Customers (MIC) and Texas Industrial Energy Consumers (TIEC), as representatives of the End-Use Customers Sector, and NIPSCO Large Customer Group (NLCG) appreciate this opportunity to provide comments to MISO.
[2] MISO provided an initial and hypothetical set of transmission lines to accommodate the expansion and estimated that the investment cost could range from $10 billion to $20 billion for the Tranche 2 portfolio.
Comments from MISO Cities and Communities Coalition Participants
on the MTEP Futures Refresh
December 15, 2022
The MISO Board of Directors
C/O John R. Bear, Chief Executive Officer
720 City Center Drive
Carmel, IN 46032-3826
Dear Members of the MISO Board of Directors:
The undersigned participants in the MISO Cities and Communities Coalition (MISOCCC) appreciate the opportunity to submit this feedback to MISO on its MTEP Futures Refresh. The MISO Cities and Communities Coalition (MISOCCC) is a coalition of communities[1] across the MISO footprint that coordinates collective action to further the individual clean energy, economic development, decarbonization, affordability, and grid reliability goals of participating communities through engagement with MISO leadership, its staff, and its stakeholders.
MISO’s MTEP23 and ongoing Long Range Transmission Planning processes will directly affect our ability to achieve our goals. As such, we look forward to working with MISO and other stakeholders to ensure the planning Futures and subsequent transmission plans deliver the right transmission projects to enable the future grid we need.
Specific Feedback for MTEP Futures Refresh
While MISOCCC supports MISO’s continued use of its existing three MTEP Futures, we note our belief that all three of the current Futures likely underestimate the market-driven pace of clean energy resource deployment.
On top of the already ambitious clean energy goals and actions of MISOCCC members, recent passage of the Inflation Reduction Act (IRA) is likely to rapidly accelerate clean energy technology adoption within MISOCCC member communities and throughout the MISO footprint. While MISO has updated the Future to include consideration of the renewable energy market impacts of the IRA, we encourage further consideration of the impacts of new incentives and different payment structures (such as the direct pay mechanism) on local government, community, and corporate renewable energy procurement.
MISO’s assumptions around the timing and magnitude of load growth, utility-scale clean energy deployment, and distributed energy resource adoption are critical to ensuring system reliability along with maintaining just and reasonable transmission rates in the MISO footprint. MISOCCC recommends MISO staff further engage with its membership to assess divergence between local goals and expected renewable energy delivery and load growth anticipated in its transmission planning processes. We encourage MISO to consider additional scenarios that account for local and state government renewable energy commitments, such as Minneapolis’ Climate Action Plan goals to reduce greenhouse gas emissions by 30% and generate 10% of its electric load from local, renewable resources by 2025 and Michigan’s commitment to carbon neutrality by 2050.
We appreciate the opportunity to provide comments, and we look forward to remaining engaged in the process. If you have any questions, please contact Stacy Miller, Sustainability Program Coordinator for Energy and Climate Regulatory Policy, at the City of Minneapolis (stacy.miller@minneapolismn.gov).
Sincerely,
The MISO Cities and Communities Coalition (MISOCCC)
Jeremy Caron
Sustainability Program Manager
City Manager’s Office, Facilities Division
City of Des Moines, Iowa
Kim Havey
Director, Sustainability
City of Minneapolis, Minnesota
Kim Keller
City Manager
City of St. Louis Park, Minnesota
Lewis Kuhlman
Environmental Planner
City of La Crosse, Wisconsin
Morgan Mickelson
Director, Office of Sustainability
City of Indianapolis, Indiana
[1] For the purposes of coalition membership, the term “community” is defined as city governments, county governments, tribal nations, regional planning commissions, etc.
Environmental Sector Comments Regarding PAC: Futures F2A Expansion Results (20221129)
The Environmental Sector appreciates this opportunity to comment on the initial Future 2A results. Broadly, we are very encouraged by the initial modeling which appears more closely aligned to many industry and other third party forecasts of future energy expansion throughout the MISO footprint. Future 2A more accurately reflects the shift towards low-cost renewable generation resources being driven by utility member plans, consumer demand, clean energy mandates, and the recently passed clean energy incentives in the Inflation Reduction Act. We appreciate MISO’s work on the Futures Refresh, and the results show the importance of regularly updating the futures’ assumptions based on the most recent information available. Relatedly, we applaud MISO’s efforts in the 2022 Regional Resource Assessment (RRA) to create a clear picture of how quickly the resource fleet is evolving and the challenges and opportunities associated with that transition.
We note, however, that the updated Future 2A is likely still too conservative given the fact that many of the member plans incorporated into Future 2A do not account for the acceleration of fleet change that will be driven by the Inflation Reduction Act (IRA). This combined with the ongoing trends of acceleration in fleet transition seen over the past decade should serve as a warning to MISO and stakeholders to remain aggressive in their assumptions and guard against being overly conservative in forecasting MISO’s generation mix. With respect to concerns of financial risk in overplanning for a future that does not manifest - as many stakeholders and MISO leadership have alluded to - we highlight the risk of being too conservative in our expectations for wind, solar and energy storage resources that carries both reliability and financial risk if we are not tracking trends appropriately. And history has shown that MISO’s future assumptions have consistently fallen short of reality.
The area where we have the greatest concern with Future 2A is the expansion of standalone energy storage resources that appear overly conservative given both queue activity and the newly enacted 30% energy storage Investment Tax Credit that has yet to be incorporated into current member plans. The table below shows state-by-state levels of stand-alone energy storage currently active in MISO’s queue, representing a total of more than 47 GW of new resources. Even factoring in an assumption of 20 percent success rate from the queue, (that staff has cited in past meetings), it raises significant concerns that Future 2A’s assumptions regarding storage deployment, particularly in the early years of the planning horizon, are overly conservative.
[For illustration, a chart provided in Environmental Sector comments sent as an attachment, based on MISO Interactive Queue Data pulled 12/8/2022 shows levels of stand-alone storage currently active in MISO’s queue]
A 20 percent success rate applied to the 47 GW of storage in the queue today would equate to 9.4 GW of installed storage. This is more than one third of the projected 27 GW that Future 2A assumes will be interconnected over the course of the next twenty years. Given that 32 GW was added to the queue this year alone, it is reasonable to believe that as much–if not more–will be added to the queue in each of the upcoming few years, suggesting that the total amount of interconnected storage could reach Future 2A’s 2042 prediction by 2030. Given the continuing increase in storage projects, we believe that MISO should adjust the planning assumptions surrounding storage in a nod towards actual trends over modeling assumptions.
Although siting has not yet been completed for Future 2A, LRTP Tranche 2 planning could be influenced greatly by incorrect energy storage assumptions, and it’s important that MISO is being as close to the mark as credibly possible. Considering that MISO North will likely not see another LRTP portfolio until Tranche 5, which looks to be at least five years away, it is paramount that MISO not be too conservative in its assumptions of storage additions.
To be clear, the Environmental Sector reiterates our strong support for MISO’s refreshed Future 2A as a critically important step in planning for a quickly evolving generation landscape, and in furtherance of robust planning for Tranche 2 of the LRTP. However, we strongly advise MISO to reconsider its battery-storage deployment assumptions given the disparity between Future 2A and the current on-the-ground landscape, especially if MISO wants to achieve a true least-regrets outcome.
Looking ahead to the updated Future 3A:
The Environmental Sector also would like to take this opportunity to provide some initial comments on the forthcoming update of Future 3, scheduled for spring of 2023.
Given the updated Future 2A, which resembles the current Future 3 in terms of scale and scope of resource fleet transition, updates to Future 3A will need to be significant to represent a true “bookend” to MISO’s planning assumptions. To that end, we offer these initial observations:
Development of offshore wind in MISO South: A diversity of stakeholders in Louisiana are increasingly involved in the BOEM process identifying Wind Energy Areas off the coast of Southeast Texas and Louisiana. Despite timelines that are lengthy for evaluation, auctioning of leases, site assessment, environmental review and deployment, it is still likely that this timeline could fit into the 20 year time horizon of the Futures. In this eventuality, it’s important to consider the impact of injections of offshore wind into the MISO South system and the transmission system needs to accommodate this new resource.
It is worth noting that offshore wind does not have to be selected in IRPs for that industry to be acknowledged in planning for the next 20 years. Some offshore wind business models are focused on non-utility off-take that will occur regardless of utility plans and would not be visible in IRP processes.In the U.S., offshore wind projects average roughly a decade from leasing auctions to in-service dates and while there are specific challenges to offshore wind in the Gulf of Mexico, we expect projects to be installed and operating before 2042. While we believe it’s appropriate for MISO to include offshore wind in Future 2A, lingering uncertainty as to the scale of offshore wind buildout, and simply internal time constraints to complete Future 2A may prohibit that. At a minimum, however, we expect offshore wind to be included in Future 3A.
Assumed carbon constraints: Future 2A assumptions will likely be close to or even beyond the 80 percent carbon reduction currently assumed in the current Future 3. MISO’s 2023 Regional Resource Assessment seems to confirm the acceleration of carbon reductions across the MISO footprint. We, therefore, believe that a robust update to Future 3A should include an assumption of 100 percent decarbonization across the MISO footprint to serve as a true bookend to MISO’s planning assumptions.
Distribution-side assumptions: The Future 3A refresh must include an update to the demand-side assumptions, including pace and scale of electrification, particularly within the transportation sector, the adoption of distributed energy resources, increased implementation of energy efficiency measures, and the use/availability of demand response. We understand the effort necessary to accomplish this, but feel it is absolutely necessary to establish a meaningful bookend Future 3A that will inform not only MISO’s LRTP, but several other initiatives underway through the reliability imperative.
We look forward to working with MISO in finalizing the updated Future 2A and re-establishing Future 3A as a true bookend to MISO’s planning process.
Thank you,
MISO Environmental Sector
Invenergy supports the Future Refresh effort and MISO’s dedication to balancing system assumptions and the uncertainties of the future. A historic pace of change can tempt rushed action and Invenergy commends MISO for taking the time necessary to thoroughly review key assumptions for Tranche 2.
As the Futures assumptions evolve, as they have since October, Invenergy encourages MISO to continue partnering with stakeholders to ensure consistency in assumptions throughout all Futures.
The draft Futures 2A results demonstrate that demand for clean energy resources has and will continue to increase. As the fleet transition accelerates, cost management for the needed infrastructure will become increasingly important to contain costs to load.
While Invenergy believes that the Grain Belt Express should be considered as base assumption in MISO’s planning process, we would urge MISO to include this advanced, late-stage project as a sensitivity in the Futures Refresh scenarios. If this advanced-stage interregional MHVDC project is excluded from any modeling, load risks paying for duplicative lines in a portfolio of already historic proportions. Further, GBX has been included in customer IRPs and anticipates executing a Service Agreement with MISO before the conclusion of the anticipated Futures Refresh (May/June 2023).
Invenergy appreciates the opportunity to provide feedback on MISO’s Futures 2A draft results.
Transmission Owners Sector Feedback on Futures F2A Expansion Results
December 16, 2022
In the November 29, 2022 meeting of the Planning Advisory Committee (PAC), MISO presented Futures “F2A” expansion results for stakeholder review and feedback. The Transmission Owners Sector (Owners) are supportive of MISO’s ongoing efforts to develop an appropriately scoped Tranche 2 portfolio incorporating refreshed Future 2A information that accurately captures the dramatic pace of change in the generation resource mix in the MISO Midwest subregion. The Owners’ additional comments, below, are intended to offer a discrete process improvement to assist MISO in identifying the most appropriate future resource needs.
Specifically, the Owners recommend below that to assess the resource needs for Future 2A, MISO supplement its Resource Forecasting process, which uses a load-duration curve-based EGEAS model, with “spot checks”, by applying a zonal chronological long-term resource expansion model prior to siting future resource additions to evaluate the sufficiency of the resource mix to meet system demand reliably at all hours for the heavily intermittent resource Futures being evaluated in the LRTP.
MISO’s use of EGEAS, a load duration curve-based model, to forecast future resource needs results in the selection a resource mix that will meet the needs of the MISO System at peak, but it does not capture hourly change in load or generation. Being a load-duration-curve model, EGEAS is generally useful in ensuring that peak demand and load energy requirements can be met with the resources selected by the model. However, EGEAS results do not reflect MISO’s operational needs in every hour; thus, the output of EGEAS does not ensure that chronological demand can be met on an hourly basis with the resource mix selected.
EGEAS selects the cheapest generation mix needed to meet load needs at peak, resulting in the inclusion of significant intermittent resources (wind, solar and storage), selected to meet annual Reserve Margin requirements, but as also noted by the IMM, not necessarily sufficient dispatchable resources to carry the load and ramping needs in daily real-time operations.
This gap in evaluation of the resource mix that is necessary to serve MISO’s hour load demands chronologically can be addressed by supplementing MISO’s preliminary future resource expansion results with a zonal chronological model prior to performing resource siting to ensure that local area needs are able to be met on an hourly basis, taking into consideration of minimum run times, up- and down-times also need to be considered, and the ability of resources to ramp up and down to meet changing demand and resource in successive hours needs to be assessed, given the high levels of intermittent resources forecasted by EGEAS.
Without performing this crucial additional step in the Futures model development process, the resource expansion plan obtained from the EGEAS model for Future 2A could be theoretically adequate, while failing to meet the increasingly challenging ramping requirements expected to be needed to accommodate (and accompany) large quantities of intermittent renewable resources to ensure the reliability of the grid. Moreover, any subsequent production cost model developed from such a resource plan with the high intermittent resources penetration resulting from the output of EGEAS will likely exhibit unserved energy and/or spinning reserve violations, some of which may be incorrectly attributed to transmission congestion or insufficient transmission capacity while analyzing the results for that Future.
To evaluate whether hourly needs are met on a chronological basis, the Owners recommend that MISO use PROMOD, PROSIM, GE MAPS, Aurora and/or EnCompass all capable of modeling hourly chronological demand and generation simulation at a zonal level, to evaluate the sufficiency of the forecasted resource mix at all hours to reliably meet system demand in the heavily intermittent resource Futures being evaluated in the LRTP. This approach would produce superior results for determining the resources assumed in the LRTP study models.
In consideration of the increased runtime required for these programs, the Owners suggest MISO run “spot checks” in 5-year increments using one of the alternate programs to bridge the gap in the resource forecast for the F2A results by performing a check on the forecasted resource mix to determine whether this resource plan meets the chronological load demand on a zonal hourly basis, or if significant unserved energy or spinning reserve violations are seen in the subsequent production cost runs.
These spot checks would enable evaluation of the significance of the anticipated issues, as well as the additional study time needed to run these programs. This information would allow MISO to assess the benefits of enhancing the current Resource Forecasting process to include additional analysis that would provide the planning capabilities needed in the future scenarios being studied by MISO in the LRTP.
The Owners request that MISO post an assumptions book, accessible to all stakeholders, that contains the following information, to assist stakeholders in reviewing key base case assumptions:
o New resource cost assumptions, generator operational parameters, book life, etc.
o Load and load growth, hourly load profile.
o Retirement assumptions
o Existing resources included in the model
We also request MISO explain whether EGEAS forecasted any generator retirements beyond those assumed by MISO to be retiring based on the assumptions established for the Futures being used for LRTP analysis. If so, please explain how EGEAS makes its retirement decisions.
Provided below are the TDU Sector’s initial thoughts on MISO’s draft Futures F2A expansion results. The Sector appreciates the opportunity to comment on the draft results and looks forward to continued discussion with MISO on this work.
Feedback from Consumers Energy IRP Team:
One of our concerns with the MISO RRA capacity expansion analysis is the fact that EGEAS (the capacity expansion tool used by MISO) uses a Load Duration Curve (LDC) in their capacity expansion modeling. By nature, LDC solves do not preserve chronology (the natural order of hours over a period of time). Instead, LDC solves re-order the hours over a given period of time from highest demand to lowest demand. This means some resource types, specifically batteries, will have their value underestimated in an LDC solve, because one of the biggest benefits they bring is the ability to balance energy between off-peak and on-peak hours within a day.
Additionally, solving using an LDC means the optimization is likely underestimating the amount of loss of load events (LOLE). This is a direct effect of not accounting for chronology; we are unable to see how the system actually performs if the system were to run in the natural order of time.
Finally, we are concerned by the fact EGEAS does not have the ability to account for seasonal construct, specifically in relation to planning reserve margins. We believe this is critical in a world where solar and wind capacity compose a more significant portion of the generation mix, as their reliable capacity contribution varies by season. This, coupled with the shift in annual peak demand to winter months, means the capacity expansion buildout is prone to more LOLE events. It sounds like MISO is aware of this shortfall and is actively evaluating models that do have this capability.
Regards,
Michael Soni
Electric Grid Integration
Electric Supply Planning and Cost Forecasting
The TDU Sector, which I represent at PAC, plans to submit feedback on this item. To facilitate the development of meaningful comments, however, we would request more information on the current F2A resource expansion results (which we understand are preliminary).
Specifically, it would be helpful to us if MISO could promptly post data underlying the graphs on slides 5 & 7 of the presentation, which show, for each future year, the MW quantities of addition and retirement by LRZ and fuel type.
Ideally, we would also like to see these data broken into EGEAS-inserted vs. LSE-planned capacity. We recognize, however, that this might conceivably compromise the confidentiality of some LSE plans. Accordingly, we would suggest that MISO provide this data, but if necessary do so only at a sub-regional rather than LRZ granularity.
We would request that MISO post this data to the 11/29 PAC meeting page.