CARMEL, Ind. — MISO will revisit its Tariff to better define how aggregators of retail customers (ARCs) participate as demand resources as more aggregators line up for market participation.
FERC in 2012 approved MISO’s ARC participation model, which lays out how end-use customer groups can offer demand response into the markets aggregated at the load-serving entity level. Rules found in Module C of the Tariff lay out aggregator registration, creation of a commercial pricing node, certification of each retail customer and the RTO’s communication of the volume of DR cleared in the day-ahead market.
“For quite a long time, we didn’t have a lot of participation, but in the last few years, we’ve had significant ramp-up,” MISO Principal Adviser of Market Design Mike Robinson told stakeholders at a Market Subcommittee meeting Wednesday.
Robinson said MISO should clarify what information ARCs need for registration and what responsibilities are required of ARCs, LSEs, relevant regulatory authorities, local balancing authorities and MISO. He also said the RTO needs a better process to avoid the double-counting of aggregated DR assets and should make clearer ARCs’ requirements around metering and settlement.
MISO also must establish a clearer timeline for ARC notifications approval deadlines, Robinson said, adding that it would reorganize the ARC section in Module C so it describes participation cohesively, from registration to settlement.
Through the edits, MISO will ensure there’s no “unfair or artificial barriers to participation” imposed on ARCs, Robinson said. He said it will especially focus on the registration process, which has been criticized as confusing by some members.
MISO is accepting stakeholder opinions on the Tariff edits through Jan. 22. Robinson said he would return to the MSC in February to discuss proposed changes.
Monitor Examining SPP’s Fall Transfer Derate
Independent Market Monitor David Patton said he continues to investigate SPP’s November request to reduce flows on the contract transmission path between MISO’s Midwest and South regions.
During a quarterly market recap, the Monitor repeated concerns about the request that MISO cut its regional dispatch transfer (RDT) limit flows to 1,500 MW on an unusually cold Nov. 13 — a move that cost the RTO an additional $876,383 in congestion that day. (See “Tricky Mid-November,” MISO Avoids Fall Emergencies.)
“It was relatively expensive for MISO to derate the [RDT limit], and we don’t have all the answers yet,” Patton told stakeholders. “Communications are continuing with SPP on this event.”
Patton said SPP should have made some sort of intermediate move, including requesting unit redispatch or transmission loading relief, before calling for a transfer limit derate.
Stakeholders asked if the Monitor was investigating compliance violations on SPP’s part.
“I think they are allowed to ask for a [derate],” Patton responded. “I think if there’s a compliance issue it may be not providing proper justification for the derate request. But that’s a minor point, I think, in comparison to the larger concern that it’s an expensive action and there are a number of better options that are less costly.”
Patton said SPP may lack incentive to provide “more surgical solutions” rather than what he described as the “blunt instrument” and “sledgehammer” of cutting flows on the regional dispatch transfer.
“Clearly SPP isn’t going to have to pay this bill to derate the RDT,” Patton said.
Stakeholders asked why MISO simply didn’t cut its non-firm exports into the Southern Co. territory at the time to avoid straining the transfer limit. Patton said cutting exports pre-emptively could have created a bigger problem for Southern, which was also struggling to furnish adequate supply in the cold.
“This gets into the nebulous area of what you do pre-contingency versus what you do post-contingency,” he added.
— Amanda Durish Cook
