Comment in Response to MISO SAWG Presentation

Posted: February 5, 2016 - 16:48 / MISO / ESA Filings

The ESA submits the following response to the SAWG solicitation for comments and questions regarding Capacity Accreditation.

ESA appreciates MISO's initiative to revisit Capacity Accreditation for different technologies and acknowledgement that gaps might exist for emerging resource technologies, including energy storage, and new variable resources. With regards to Capacity Accreditation, I hope the following initial thoughts will be relevant to your undertaking. (We are currently submitting comments to the feedback requested in the MISO MSC Energy Storage workshop as well.)
•    A Generator can potentially be Use Limited Resource for capacity payment. 
•    The rules on the use of storage as capacity resource are not clear. Can MISO provide more information on the process that will have to be followed by a potential developer in order for an energy storage resource to receive capacity credits?
•    In the Resource Adequacy BPM, MISO appears to consider Generation Resources, External Resources, and Demand Response Resources backed by behind-the-meter generation only as Use Limited Resources, whereas the Module A defines Use Limited Resource as "Generation Resources or External Resource(s), that due to design Considerations, environmental restrictions on operations, cyclical requirements, such as the need to recharge or refill, or for other non-economic reasons, are unable to operate continuously on a daily basis, but must be able to operate for a minimum set of consecutive operating Hours." Based on the definition in Module A, energy storage should be considered as a Use Limited Resource and be eligible for all opportunities available to other resources in BPM. Can you please clarify and/or rectify this ambiguity?