UNINSTRUCTED DEVIATION Stakeholder Presentation. MISO Market Subcommittee February 8, 2018
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1 UNINSTRUCTED DEVIATION Stakeholder Presentation MISO Market Subcommittee February 8, 2018
2 AGENDA F THE UNINSTRUCTED DEVIATION (UD) STAKEHOLDER UPDATE Executive summary UD Timeline Stakeholder Involvement Framing the Issue Comparison of Proposals Next Steps Appendix MISO/IMM recommendation (Nov 2016) with Risks and Mitigation Alternative 1 with Risks and Mitigation Alternative 2 with Risks and Mitigation Alternative 3 with Risks and Mitigation 2
3 EXECUTIVE SUMMARY Purpose: To raise awareness of collaborative efforts to date regarding uninstructed deviation (UD), share alternatives to the MISO/IMM recommendation (Nov 2016), and present identified risks with potential mitigations Key Takeaways: Stakeholders support a UD change to incentivize the correct market behavior Stakeholders developed and proposed three alternatives and continue to meet twice a week to work towards the UD common goal MISO/IMM continues to show interest in the stakeholder group efforts through meeting participation and a revised proposal 3
4 UD TIMELINE AT MSC November 2016 MISO presented the MISO/IMM recommendation of basing UD on ramp rate September 2017 MISO presented specific resource data from its analysis of the MISO/IMM Nov 2016 UD recommendation October 2017 MISO sought stakeholder recommendations Ameren presented concerns with the MISO/IMM Nov 2016 recommendation November 2017 IMM responded to stakeholder questions MISO/IMM affirmed its intent to move forward with its Nov 2016 recommendation December 2017 MISO reported its ongoing work with stakeholders January 2018 No MSC update, but stakeholders continued to develop alternatives 4
5 COLLABATION OF STAKEHOLDERS, MISO, AND IMM Participating members to date include: DTE Energy MidAmerican Energy Company Dynegy Wind on the Wires Ameren Great River Energy Big Rivers Electric Corporation NIPSCO Alliant Xcel Energy Entergy NextEra Consumers Energy And we welcome more input from others! 5
6 SIGNIFICANT STAKEHOLDER INVOLVEMENT Stakeholders have invested a substantial amount of time and effort since November 2017 to: Identify operational challenges for all resource types Identify tariff issues that are barriers to performance Develop alternate UD proposals Evaluate these proposals quickly, many times within a week Determine the top three alternatives Meet with MISO weekly to ask questions and communicate progress Meet with MISO and the IMM for an in-depth meeting on operational and market issues PURPOSE Develop a balanced UD approach that requires resources to follow dispatch signals within the constraints of operational and market issues 6
7 PARTICIPATING STAKEHOLDERS AGREE TO THE COMMON GOAL BUT WANT TO ENSURE THERE ARE NO UNINTENDED CONSEQUENCES Common Goal Units should respond to dispatch signals; units that don t respond should not receive undeserved make whole payments Gap to Reaching Common Goal Any solution must consider the operational limits of resources, including wind forecasting, coal mill and boiler feed pump limits, etc. 7
8 STAKEHOLDERS HAVE PROPOSED VARIOUS ALTERNATIVES TO THE MISO/IMM NOV 2016 UD RECOMMENDATION THAT ARE INTENDED TO MEET THE GOAL WITHOUT UNDULY PENALIZING UNITS THAT ARE SHOWING GOOD FAITH EFFTS Variable Current MISO/IMM Nov 2016 Proposed Proposal #1 Proposal #2 Proposal #3 Description Calculation Max Min Calculation based on % of setpoint 8% of Setpoint Calculation based on half of offered ramp rate Min of 2.5 * Ramp Rate 10% Setpoint Adopt the MISO/IMM Nov 2016 recommendation but increase the ramp rate multiplier and remove the 10% Setpoint 7.5 * Ramp Rate Retain current methodology, but with tighter tolerances 6% Setpoint Energy Mileage concept measures how much a unit actually moved over a one hour period compared to how much it was asked to move Percentage threshold of desired Energy Mileage Performance Metric 30 MW 30 MW 30MW 20 MW NA 6 MW 6 MW 6 MW 6 MW A tolerance band All proposals retain logic for four 5-min FFDFs in a row before receiving an FFDF for the hour Proposal details presented in the Appendix 8
9 OPERATIONAL CHARACTERISTICS AND TARIFF ISSUES CREATE UNINTENDED RISKS Risks Units unable to offer full flexibility across operating range Loss of operational awareness Units offer most restrictive ramp rate DA yielding to suboptimal results for load Deviations caused by MISO forecast errors of renewable resources should not be penalized Meeting dispatch may depend on data used to calculate UD Meeting dispatch may not be achieved when dispatching between Ecomax and Regmax UD changes do not consider 5-min settlement changes Potential Mitigation Implement an Energy Mileage concept to incentivize units to offer dispatch flexibility Simplify UD calculation Tariff updates related to PVMWP eligibility for units using RT ramp rate curves Eliminate10% of setpoint criteria and prioritize work on IMM's recommendation for wind concurrently with this project Parallel test with stakeholders prior to implementation Eliminate control status changes intra hour Ensure proposed changes consider 5- minute settlements 9
10 NEXT STEPS INCLUDE A CONTINUED COLLABATIVE EFFT BETWEEN MISO, THE IMM AND STAKEHOLDERS TO DEVELOP A WIN-WIN SOLUTION Today Next Stakeholder Presentation followed by MISO/IMM Presentation on a new revised UD recommendation Continued collaboration with increased stakeholder participation to review and evaluate the revised MISO/IMM proposal and provide feedback and proposed modifications End MISO/Stakeholder parallel testing and implementation 10
11 APPENDIX 11
12 MISO/IMM November 2016 Proposal Variable Description Max Min Current Calc. based on % of setpoint MISO/IMM Proposed Nov 2016 Require half of offered ramp rate 30 MWs 30 MWs Max of 6 MWs 8% of Setpoint Max of 6 MWs 2.5 * Ramp Rate 10% Setpoint The MISO/IMM's proposed tolerance bands, specifically around the 2.5 * Ramp Rate criteria, becomes restrictive for large units with low ramps rates Benefits Reduces Price Volatility Make Whole Payments to generators Stakeholders have significant concerns with this option without changes to address associated risks * All proposals retain logic for 4 5-min FFDFs in a row before receiving an FFDF for the hour 12
13 Proposal: Alternative #1 Ramp Rate Proposal with Adjustments Variable Current Proposal #1 Description Max Min Calc. based on % of setpoint Adopt the MISO/IMM Nov 2016 recommendat ion but with a higher ramp rate multiplier 30 MWs 30MWs Max of 6 MWs 8% of Setpoint Max of 6 MWs 7.5 * Ramp Rate Maintains the IMM/MISO proposal to base the threshold on ramp rates, but more accurately reflects actual dispatch process without penalizing fast ramping resources and still can detect if units are failing to move Benefits Maintains MISO/IMM methodology detecting units who are failing to respond Reduces the penalization of units with smaller ramp rates during good faith efforts to move to setpoint while eliminating units dragging on the system from benefiting from it with undeserved make whole payments Allows generators to move through equipment points and does not penalize fast ramping renewable resources * All proposals retain logic for four 5-min FFDFs in a row before receiving an FFDF for the hour 13
14 Proposal: Alternative #2 Tighten Existing Uninstructed Deviation Threshold Variable Current Proposal #2 Description Calc. based on % of setpoint Retain current methodology, but with tighter tolerances Provides a more reasonable reduction from existing methodology (33% reduction for larger baseload units), while maintaining operational awareness Max Min 30 MWs 20 MWs Max of 6 MWs 8% of Setpoint Max of 6 MWs 6% Setpoint Benefits Maintains known and accepted methodology, yet is a significant tightening of the tolerance band Maintains operational awareness * All proposals retain logic for four 5-min FFDFs in a row before receiving an FFDF for the hour 14
15 Proposal: Alternative #3 Energy Mileage Variable Current Proposal #3 Description Max Min Calc. based on % of setpoint Introduce new Energy Mileage concept Measures how much a unit actually moved over a one hour period compared to how much it was asked to move 30 MWs NA Max of 6 MWs 8% of Setpoint of (Max of X MWs Y * Ramp Rate) combined with Z% of desired Energy Mileage Performance Metric The Energy Mileage approach benefit units that are making a good faith effort to move and follow setpoint within the hour interval Benefits New and unique approach that should benefit units that are making a good faith effort to move and follow setpoint. Modeled on similar principles of regulation mileage, providing a measure of consistency between energy and regulation products. Energy Mileage could be considered a measure of performance, and could also address future considerations for a PVMWP performance metric (as addressed in Market Roadmap item 58). A tolerance band is needed to eliminate the noise of very small requested movements * All proposals retain logic for four 5-min FFDFs in a row before receiving an FFDF for the hour 15
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