By Amanda Durish Cook

CARMEL, Ind. — MISO plans to file a reworked version of its pro forma pseudo-tie agreement this month after FERC rejected a previous proposal earlier this year.

The commission’s February order rejecting the earlier agreement in part found fault with MISO’s proposed suspension and termination provisions. (See FERC Rejects MISO Pseudo-Tie Pro Forma.)

This time MISO will file two separate pro forma agreements with FERC: one for generators pseudo-tying into the RTO and one for generation pseudo-tying out, Principal Engineer Kyle Abell said during a May 31 Reliability Subcommittee meeting. He said the two separate agreements will clarify the responsibilities of both MISO and the external balancing authority.

Additionally, MISO says it will coordinate the suspension and termination of pseudo-ties with external BAs and follow suspension processes outlined in joint operating agreements with those BAs, if they exist.

Identical provisions in both versions of the agreement would allow MISO to suspend a pseudo-tie if it poses a reliability risk, violates the Tariff or any applicable joint operating provisions, breaches the pro forma, or fails to provide required real-time data to the RTO. MISO may also terminate pseudo-ties when they are subject to two or more suspensions during a 30-day period.

Each of the agreements provides pseudo-tie owners up to 30 days to resume normal operation from suspended status when they provide “a remedy for the cause of the failure.”

MISO could also terminate an agreement after a 60-day notice if it determines that the “existing market design does not accommodate the pseudo-tie.” It also retained provisions to suspend or terminate pseudo-ties that do not maintain firm transmission service from source to sink for the life of the pseudo-tie or cannot maintain a generation-to-load distribution factor within 2% between MISO and an external balancing authority area.

During a May 30 MISO-PJM Joint and Common Market meeting, PJM’s Tim Horger said there wasn’t much left to report on the RTOs’ overall pseudo-tie coordination plan, which he called a “good thing.”

“A lot of the pseudo tie initiatives have come to a conclusion,” Horger said.

MISO and PJM hope to implement the first phase of a previously announced fix to the double-counting of pseudo-tie congestion charges by Aug. 1, although FERC has not yet ruled on the RTOs’ rebate solution filed in late October 2017. (See MISO, PJM Pursue Pseudo-Tie Double-Charge Relief.)