In terms of managing the system in real time, the increasing penetration of LMRs limits MISO's ability to effectively and efficiently use all the resources that are committed under the region's capacity construct. This is partly due to a lack of sufficient locational information. Further, LMR access comes via Emergency Operating Procedure (EOP) activation at Step 2a, when conditions are volatile due to stakeholder responses to earlier emergency declarations, both within MISO and other Balancing Authorities. Additionally, MISO is limited to five LMR deployments per planning year, so use must be judicious. Lastly, LMRs are only obligated to be available during the summer season. LMR deployment is not a simple calculation. A single CPNode may cover a vast area of the reliability footprint thereby limiting system operation’s ability to know exactly how and to what extent LMR deployment will help mitigate an emergency. More precise locational information will improve MISO’s ability to mitigate system emergencies. In addition, there is a disparate and different set of tools used to Load Curtailment manage LMRs versus traditional generation. Traditional generation is dispatched via the Day-Ahead Real-Time (DART) Energy Markets Operating System versus LMRs, which are committed through a component of the MISO Communication System (MCS). Better locational information and a single platform for commitment/dispatch of traditional generation and LMRs would allow LMRs to be used for congestion management and to relieve constraints. From a market perspective, LMRs are also treated differently. Traditional generation uses a different testing and performance penalty structure for nonperformance compared to LMRs. Also, while there have been recent tariff changes on rules for utilizing LMRs more effectively, they are still only obligated to be called upon five times per Planning Year. These issues are complex as MISO markets, operations and the broader Bulk Electric System (BES) have evolved and changed significantly since the introduction of LMRs to the MISO Tariff. As LMRs continue to displace traditional generation as a percentage of total resources and are utilized more frequently, there is a need to evaluate if it is appropriate to continue to treat them differently, while also understanding the limitations in doing so. Load Modifying Resource (LMR) is a category that refers to the use of a demand resource toward meeting Planning Resource Margin Requirement (PRMR) Next Steps MISO will engage with stakeholders to: • Explore LMRs performance and impacts during MaxGen emergencies Emergency Demand Response (EDR) is a service that refers to the use of a demand resource under a specific Tariff schedule. Demand Response Resource (DRR) refers to a resource type; one that provides service to the energy and ancillary services market. • Generate options for process improvements to provide better visibility into LMR availability • Engage stakeholders to evaluate options for operational and planning enhancements 11
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