By Amanda Durish Cook
FERC on Tuesday rejected a MISO proposal to streamline the RTO’s process to define and qualify its network resources, saying the changes would cause Tariff discrepancies.
“MISO’s proposed revisions … lead to inconsistencies in its Tariff,” FERC said in denying the filing without prejudice (ER18-502).
MISO filed the change in December to eliminate a requirement that Network Resource Interconnection Service (NRIS) generators must be qualified as a designated network resource in the RTO’s Open Access Same-Time Information System (OASIS). MISO also proposed to remove a provision requiring network customers to “un-designate” extra capacity on OASIS before offering it into the RTO’s markets and annual capacity auction.
The revisions would have reduced the information customers have to provide on Network Integration Transmission Service applications, including maintenance records and whether a unit will be an internal resource. MISO characterized the requirements as nothing more than “administrative steps.”
MISO said NRIS resources already demonstrate their deliverability publicly, adding that it generally doesn’t perform an additional study when network load designates a resource with NRIS. The RTO said the move would cut down on the amount of “duplicative information” it receives and increase efficiency for itself and market participants. MISO added it had “no downstream processes that rely on the designation information of NRIS resources.”
But FERC said MISO’s plan as worded could introduce confusion among its customers.
The commission noted MISO’s proposed changes interchangeably use the terms “network load,” “transmission provider’s network load” and “network customer’s network load.” FERC had originally asked for clarification on the filing in February on similar use of the terms, and MISO responded by taking out some, but not all, of the language.
“These changes could lead to a misunderstanding of the ownership of network load,” the commission said in the May 29 order.
The Missouri Joint Municipal Electric Utilities Commission and WPPI Energy protested MISO’s filing, saying the proposed changes appeared to “erode” and “hollow out” the RTO’s current obligation to plan and provide for the firm delivery of network resources to network load economically dispatched and regulated by network customers who pay MISO’s load-ratio network service charge.
FERC said it would not address those concerns since MISO could not demonstrate its revisions were just and reasonable. MISO had contended that the two organizations misunderstood its revisions.