Resource Adequacy  ·  MISO Region  ·  2026

Strengthening Resource Adequacy with FTM Distributed Batteries

A market analysis evaluating how Distributed Capacity Procurement (DCP) can materially improve resource adequacy for MISO utilities — using a major regional utility as a case study for 200 MW of front-of-the-meter distributed battery deployment.

+2.4%
Utility Co's Accredited Capacity Buffer
+1.1%
LRZ 1 Reserve Margin
190 MW
Accredited from 200 MW
+4.2%
Utility Co's Capacity Gain (500 MW, 2031)

DCP Deploys FTM Batteries Now,
Capturing Wholesale Value Without Order 2222

With Distributed Capacity Procurement (DCP), utilities can plan, deploy, and dispatch medium-sized (1–3 MW), front-of-the-meter distributed batteries at scale — beginning immediately, without telemetry, using MISO's existing LMR and DRR Type 1 participation models.

Key Findings
Immediate deployment: A DCP can deploy 200 MW of battery storage in MISO without needing telemetry, beginning today and completing within 3 years.
Materially strengthens reserves: 200 MW delivers 190 MW of accredited capacity, increasing Utility Co's reserve margin by 2.4 percentage points — approximately 780% more MWs in the capacity buffer.
LRZ 1 impact: Capacity buffer rises from 1,953 MW to 2,143 MW — a 9.7% increase in reserve MW — adding 1.1 percentage points to the summer 2024 reserve margin.
DLOL-resilient: Under projected DLOL standards, a full 500 MW deployment completed by 2031 increases accredited capacity by at least 4.2%, positioning DCP assets above the 62% class-level floor.
Portfolio synergies: DCP creates synergies with larger storage systems and Virtual Power Plants for increased grid utilization and maximized asset value.
DCP is a strategic portfolio product that delivers critical local grid services — including congestion relief and targeted capacity additions exactly where needed — while creating synergies with larger storage systems.
200 MW
Target Deployment
FTM distributed batteries, deployable in 3 years with no telemetry required.
95%
Accreditation Rate
Pre-DLOL capacity credit attributed to DCP storage assets in current planning year.
780%
More MW in Buffer
Increase in capacity buffer MWs versus Utility Co's current position without DCP.
2028
DLOL Deadline
Window to deploy before MISO's DLOL methodology sharply reduces storage accreditation.
What is DCP? — Distributed Capacity Procurement is a model for utilities to plan, deploy, and dispatch front-of-the-meter distributed batteries at scale. DCP assets are strategically sited on utility feeders that peak coincidentally with the MISO system, delivering both local distribution value and bulk system accredited capacity from the same assets.

MISO Utilities Face a Converging Resource Adequacy Crisis

MISO has lost approximately 9.5 GW of accredited capacity over the past decade as thermal plants retire. Simultaneously, load growth is driving utility obligations higher while a new accreditation methodology is set to erode renewable capacity credits.

Now → 2030
Thermal Retirement Wave
From 2026 to 2030, 1,708 MW of coal generation in a major MISO utility's portfolio is projected to retire, shrinking the accredited capacity base and widening the resource gap.
By 2035
Peak Load Surge
MISO peak load expected to grow to ~130 GW, with renewables representing ~40% of generation capacity — but with lower, more volatile accreditation rates that don't keep pace with nameplate growth.
2028 / 2029
DLOL Methodology Shift
MISO's upcoming Direct Loss of Load (DLOL) methodology will significantly reduce capacity credits for renewables — solar falling from 50% to as low as 21% in certain seasons — and dropped energy storage class-level accreditation from 95% to 62% in PY 2025–26.
Ongoing
Seasonal Accreditation Complexity
Seasonal accreditation is changing capacity credits by season, particularly impacting renewables and altering resource adequacy requirements across summer and winter periods.
The capacity crunch: Between rising demand and planned retirements, Utility Co faces growing risk of a capacity shortfall unless additional dispatchable resources are procured in time. Traditional procurement timelines — nuclear (15+ years), large-scale gas (5–7 years) — cannot fill this gap fast enough.
Capacity Accreditation by Resource Type
How MISO's evolving DLOL methodology changes capacity credit across three planning periods — with storage and renewables most affected
Storage accreditation: 95% → 62% — In PY 2025–2026, MISO dropped class-level storage accreditation sharply. DCP assets — sited for peak coincidence and dispatched for system benefit — are positioned to earn unit-level accreditation above this class floor.

How DCP Addresses the Resource Adequacy Gap

DCP deploys now — capturing wholesale market value, delivering local grid services, and building accredited capacity before DLOL changes take full effect in 2028.

No Telemetry Required
BESS participate via LMR and DRR Type 1 models, enabling immediate deployment at scale without the delays and costs of telemetry integration.
Targeted Placement
Assets sited on feeders with peak coincidence to the MISO system, ensuring capacity value accrues during the hours that matter most for accreditation.
Distribution Value
Congestion relief and targeted capacity additions average $30–$100/kW-yr across identified circuits — value remote, utility-scale resources cannot deliver.
DLOL-Resilient
Unit-level performance history positions DCP assets for individual DLOL values above the 62% class-level floor, once MISO reaches 30 BESS for statistical analysis.
Dispatchable Capacity
Unlike variable renewables, DCP assets dispatch on-demand during peak risk hours — ensuring consistent, predictable capacity value across all seasons.
Ecosystem Synergies
Maximizes value alongside larger storage systems and Virtual Power Plants, increasing grid utilization and maximizing asset value across the full storage ecosystem.
DLOL Accreditation Trajectories
Capacity credit trends across three MISO accreditation periods for storage, solar, wind, and nuclear — highlighting storage's relative resilience and DCP's strategic upside
Note: As of October 2024, MISO has 21 BESS. Until MISO reaches 30 BESS, storage class-level accreditation remains fixed at 95%. Individual DCP assets can eventually receive unit-level DLOL values based on actual performance during peak risk hours.

DCP Strengthens Reserve Margins at Every Level

A 200 MW FTM distributed battery deployment — completable in 3 years — delivers measurable reserve margin improvements at the utility, local resource zone, and MISO system-wide levels simultaneously.

+2.4%
Accredited Capacity Buffer
≈ 780% more MW in Utility Co's reserve buffer (Summer 2023)
+1.1%
LRZ 1 Reserve Margin
Buffer: 1,953 MW → 2,143 MW (+9.7%) — Summer 2024
+0.2%
MISO System-Wide Margin
From a single utility's 200 MW deployment — Summer 2024
Utility Co Accredited Capacity Buffer — % (Summer 2023)
Reserve margin buffer above PRMR: cleared resources only vs. cleared resources + 200 MW DCP. +2.4 percentage point improvement.

* 200 MW DCP accredited at 95% UCAP = 190 MW actual capacity. Cleared resources = extra accredited capacity above PRMR UCAP obligation.

* Utility Co PRMR UCAP derived using LRZ 1 Summer 2023 PRM UCAP base obligation. Wind/Solar PPAs calculated with 2023 DLOL derates.

Utility Co Accredited Capacity Buffer — MW (Summer 2023)
Absolute MW capacity buffer above PRMR obligation — before and after 200 MW DCP deployment. +190 MW of accredited capacity added.

* ICAP converted to UCAP using MISO Capacity Credit Report estimates. Utility peak assumed nearly coincident with MISO system-wide peak.

LRZ 1 Reserve Margin (Summer 2024)
LRZ 1 cleared resources vs. cleared resources + 200 MW DCP. MISO PRMR requires each LRZ to maintain at least 109% of peak load; 9% PRM UCAP base shown.

* PY 24-25 Summer 2024 PRM UCAP is 9%. Buffer rises from 1,953 MW to 2,143 MW — a 9.7% increase in reserve MWs.

MISO System-Wide Reserve Margin (Summer 2024)
MISO cleared resources vs. cleared resources + 200 MW DCP deployment. 9% PRM UCAP requirement shown. +0.2 percentage point system-wide improvement.

* Medium-sized distributed batteries (1–3 MW) offer increased system utilization across all non-peaking hours: congestion relief, ancillary services, production cost savings.

DCP Accredited Capacity & Reserve Margin Impact
Accredited MW delivered at each deployment phase (bars) and cumulative reserve margin improvement (line) — DCP contribution shown at full scale
Accredited MW
% Buffer Increase
47.5 MW
Year 1 · 50 MW deployed
95 MW
Year 2 · 100 MW deployed
190 MW
Year 3 · 200 MW deployed
310 MW
Year 6 · 500 MW (post-DLOL)

Positioned to Capture Value Through MISO's Evolving Framework

MISO is reshaping how capacity value is determined. DCP's FTM distributed storage is uniquely positioned within this evolving construct — dispatchable during peak risk hours, strategically sited for coincident peak, and eligible for unit-level accreditation above the class floor.

Evolving DLOL Framework
In anticipation of the 2028/29 DLOL implementation, MISO annually revises its DLOL values. The 2025–26 planning year dropped energy storage class-level accreditation sharply, from 95% to 62%.
Individual storage resources will eventually be assigned their own DLOL value based on system performance, once sufficient historical data is available — creating an opportunity for high-performing DCP assets.
DCP's FTM distributed storage is well-positioned because DCP assets are strategically sited on feeders that peak coincidentally with MISO — dispatching for local peak reduction simultaneously benefits the bulk system.
In contrast to customer-owned, behind-the-meter storage, DCP assets are devoted to system needs — positioning them to capture unit-level accredited capacity above the 62% class allocation.
Even with MISO's change to DLOL, a fully completed DCP deployment of 500 MW increases Utility Co's accredited capacity by 4.2%, at minimum, in 2031.
Resource TypePre-DLOLDLOL 23/24DLOL 25/26Outlook
Gas91%88%88%Stable
Coal92%91%89%Gradual Decline
Nuclear95%90%94%Stable
Storage (DCP)95%94%62%*Unit-Level Upside
Solar45%36%38%Declining
Wind18%11%8%Sharp Decline

* Class-level floor only. DCP assets positioned for unit-level accreditation above 62% based on peak-coincident dispatch history.

DCP Accredited Capacity Across Deployment Timeline
Accredited capacity at each DCP milestone as MISO transitions from ELCC to DLOL — demonstrating the value of early deployment before accreditation changes

* 50 MW (2026) and 100 MW (2027) use 95% credit. 200 MW (2028) reflects DLOL transition. 500 MW (2031) uses 62% Even Loss method.

* Year 6 reflects 500 MW × 62% = 310 MW accredited. Earlier years: 50 × 95% = 47.5, 100 × 95% = 95, 200 × 95% = 190.

Accreditation Under DLOL 25/26: DCP vs. Renewables

Storage / DCP (class floor)62%
Nuclear (DLOL 25/26)94%
Solar (DLOL 25/26)38%
Wind (DLOL 25/26)8%

Unique Value Streams Only FTM Distributed Batteries Can Provide

Over 3 years, a 200 MW DCP deployment delivers strategic distribution system value that utility-scale and behind-the-meter resources simply cannot replicate — from accredited capacity to congestion relief to ancillary services revenue.

Boosts Reserve Margin
200 MW aggregated output increases LRZ 1's summer 2024 reserve margin by approximately 1.1 percentage points, materially reducing Utility Co's capacity procurement obligation.
Distribution Capacity Value
Distribution capacity value averages $30–$100/kW-yr across identified circuits, enabling targeted deferral of costly distribution infrastructure upgrades.
Deploy Before 2028 DLOL
DCP deploys storage assets before DLOL implementation, locking in higher accreditation rates and building unit-level performance history for favorable long-term accreditation.
Incremental Capacity
200 MW of nameplate capacity delivers value across a 36-month timeline, contributing accredited capacity to system needs from the first deployed asset.
Ancillary Services
Medium-sized distributed batteries provide ancillary services on all non-peaking hours — frequency regulation, spinning reserves — delivering additional value to ratepayers across the full dispatch stack.
Congestion Relief
Locally sited assets deliver targeted T&D congestion relief — providing reliability benefits that remote, utility-scale resources cannot achieve, maximizing every deployed asset's system impact.

DCP: A Strategic Imperative for MISO Utilities Facing the Capacity Gap

Between rising demand and planned retirements, MISO utilities face a growing capacity shortfall unless dispatchable resources are procured now. DCP is the fastest path to meaningful accredited capacity — deployable within 3 years, without telemetry, at a scale that moves the needle on reserve margins today.

+2.4%
Accredited Capacity Buffer
From a 200 MW deployment in 3 years — approximately 780% more MW in Utility Co's reserve buffer (Summer 2023)
190 MW
Accredited Capacity (200 MW deployed)
At 95% capacity credit under current MISO ELCC framework, before DLOL takes effect
+4.2%
Minimum Capacity Gain by 2031
500 MW fully deployed, using 62% Even Loss method — DCP remains accreditation-positive through DLOL transition
500 MW
Full ICAP Deployment Potential
Full DCP buildout by 2031, with each phase contributing incremental accredited capacity from day one

Citations & References

This analysis draws on publicly available MISO data, regulatory filings, industry research, and historical generation asset data from the utility subject of the case study.

1.NERC. Long Term Reliability Assessment 2024, November 2024.
2.NERC. Planning Reserve Margin, 2024.
3.NERC. Short-Term Reliability Assessment 2025, June 2025.
4.NERC. 2025 Summer Reliability Assessment, May 2025.
5.S&P Global. Interview: Distributed Capacity Procurement Can Transform Energy Landscape, June 2025.
6.S&P Global Market Intelligence. Outlook 2025: MISO To See Net Addition of 9 GW, April 2025.
7.U.S. DOE. Sourcing DER for Distribution Services, December 2024.
8.U.S. EIA. Annual Electric Power Industry Report, Form EIA-860, September 2025.
9.U.S. EIA. Annual Electric Power Industry Report, Form EIA-861, 2024.
10.Utility Dive. Distributed Capacity Solution: Empowering Utilities to Lead the Energy Transition, July 2025.
11.Utility Dive. NERC, MISO Reliability Market Monitor FERC Capacity, June 6, 2025.
12.MISO. 2024 Resource Adequacy Report, June 2024.
13.MISO. Indicative DLOL Results PY 2025–2026, June 2025.
14.MISO. Long-Term Load Forecast Whitepaper, December 2024.
15.MISO. LOLE Study Report PY 2024–2025, 2024.
16.MISO. PY 2025-2026 LOLE Study Report, March 13, 2025.
17.MISO. Accreditation Presentation (RASC), January 2024.
18.MISO. 2023 Regional Resource Assessment Report, 2023.
19.MISO. Business Practice Manuals, 2025.
20.ACP/Aurora. BESS Benefits Analysis – MISO, July 2025.
21.American Clean Power Association. U.S. National Power Demand Study, March 7, 2025.
22.World Resources Institute. Powering the US Data Center Boom, September 16, 2025.
23.Construction Physics. Batteries Are Making the Electrical Grid Work Again, June 2025.
24.Historical EAI data from Utility Co using respective accreditation values.
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