By Amanda Durish Cook

CARMEL, Ind. — MISO is wrapping up implementation of recently approved outage rules designed to dissuade capacity resources from taking long outages that could risk supply.

Approved last month by FERC (EL19-102, ER20-129), the new rules will be inserted into MISO’s Business Practice Manuals. The changes will allow the RTO to prevent a capacity resource from participating in the Planning Resource Auction if the resource plans to take an outage for more than 90 cumulative days of the first 120 days of the planning year (June 1 to Sept. 30). MISO deems the first four months as the most critical in terms of demand. (See MISO Eases New Rules on Extended Outages.)

Speaking at the Resource Adequacy Subcommittee’s meeting Wednesday, Tim Bachus, MISO capacity market administration analyst, said the policy change will be in place for the April PRA.

Nearly final BPM language states that the rule applies to “resources with pending full or partial outages that are planned and/or scheduled and reasonably expected to encompass” 90 or more days of the first 120 days of the planning year. MISO has committed to reviewing outages and derates prior to opening the PRA offer window to determine which capacity resources might be excluded from the auction.

“Market participants with resources that are affected by this rule will be given the chance to adjust those planned outages/derates to permit PRA participation,” MISO said.

Gabel Associates’ Travis Stewart said that MISO’s plan still “doesn’t have any teeth” and criticized the lack of consequences for resources that aren’t candid ahead of time regarding their availability.

MISO counsel Jacob Krouse pointed out that there are other protections against such behavior, notably the ability of the RTO’s Independent Market Monitor to notify FERC’s Office of Enforcement about resources that exhibit signs of withholding.

MidAmerican Energy’s Greg Schafer said it would be troubling if MISO began establishing penalties in BPMs that weren’t included in proposals to FERC. “We’re always concerned about things creeping into the BPM that were explicitly excluded from the Tariff,” he said.

FERC last month granted a Feb. 1 effective date for the plan. The commission’s order also dismissed as moot Wolverine Power Supply Cooperative’s September complaint that the rules lacked adequate consequences for planning resources that take extended outages.

The co-op had argued that the Tariff was unjust and unreasonable because it allowed a resource to participate in the PRA even when taking an approved outage for the entire planning year — including a large resource in Michigan that bid into the 2019/20 auction. As a rule, MISO doesn’t reveal which generators plan outages, citing confidentiality.

“MISO’s proposed Tariff revisions address this problem by ensuring that resources that are unavailable for the entire planning year will not qualify for participation in the auction or inclusion in a fixed resource adequacy plan. By specifically addressing resource availability during the first 120 days of the planning year, which begins June 1, MISO’s approach is consistent with current loss-of-load expectation study parameters, which indicate that the highest risk of resource adequacy concerns occurs generally from June through September,” FERC said.

Bachus said other than in that one instance, MISO doesn’t typically see capacity generation taking substantial outages.

MISO staff have said the temporary change is only meant for the 2020/21 PRA, though Bachus said the RTO could keep it in place for the 2021/22 cycle.