By Amanda Durish Cook
FERC has questions on MISO’s plan to transform its retirement notification process into a catch-all three-year suspension period.
The commission on Wednesday issued a deficiency letter ordering MISO to provide more specifics and an explanation of how it currently plans for suspension and retirements within 30 days (ER18-1636).
MISO this spring proposed that generation owners planning to retire or suspend their units submit a catch-all suspension notice that would have the RTO terminate their interconnection rights after three years of inactivity. (See “Matching Modeling with Proposed Retirement Process,” MISO Planning Subcommittee Briefs: June 12, 2018.)
The commission wants to know how MISO’s open-ended suspension plan may affect its process for designating system support resources — those scheduled for retirement that the RTO needs to keep operating for reliability. It asked MISO whether it would model units in the catch-all as three-year suspensions or permanent retirements.
FERC also asked how MISO currently plans for uncertainty in its suspension and retirement process. In a second filing June 21, MISO told FERC that “the future status of a suspended generator is usually unknown, and the requirement to specify an end-date when the return to service is actually uncertain can lead to false assumptions and unreasonable assurance regarding future developments.”
“For planning purposes, what assumptions are made about a generator’s future status under the current suspension provisions, and how will those assumptions change given this proposal?” FERC asked. The commission also asked MISO to explain how generators’ information on their future status may be unreliable and told MISO to provide it with five years of data on the outcomes of generators that entered suspension. FERC also ordered MISO to explain the difference between how it currently treats suspensions versus retirements in transmission planning.
Earlier this year, Economic Studies Senior Engineer Tim Kopp said less than a third of generators return to service after submitting Attachment Y notices to MISO, and that treating all suspending generation as if it will never return would make for better modeling in transmission planning.
FERC also asked if MISO intends to keep its current 26-week minimum notice requirement for Attachment Y filings.
