By Amanda Durish Cook

CARMEL, Ind. — Several MISO stakeholders are criticizing Tariff filings the RTO plans to make by the end of the year to free up an additional 5 to 10 GW of capacity in time for the spring outage season.

The discord played out in meetings as part of MISO Board Week and during a special conference call of the Reliability Subcommittee on Dec. 7.

At the Dec. 5 Advisory Committee meeting, Reliability Subcommittee Vice Chair Ray McCausland, of Ameren, said MISO worked unusually fast on the short-term resource availability and need filing.

“For those used to MISO running at the lightning pace of a glacier, MISO has flown through this,” he joked. McCausland also acknowledged stakeholder concerns about the pace of the filing. He said a few have voiced skepticism that the new load-modifying resource (LMR) treatment and outage coordination can in fact free up the capacity the RTO has cited as the reason for the Tariff filing.

Earlier this month, several stakeholders criticized MISO’s plan to require more testing of and data from certain LMRs and impose stricter notification times for planned outages. (See Stakeholders Critical of MISO Resource Availability Filing.)

Because of stakeholder pushback, the RTO said later in the Dec. 7 conference call that its originally planned Tariff filing will now become three separate Tariff filings: one each for demand response capability testing, LMR seasonal availability documentation and a new 120-day notice time for planned outages.

Kevin Murray, representing the Coalition of MISO Transmission Customers and the Eligible End-User Customers sector, called the original filing “controversial.” He said a full filing runs the risk of garnering so many protests that FERC will refuse to act on it, especially considering a D.C. Circuit Court of Appeals ruling last year that the commission overstepped its authority in its approval of PJM revisions to its minimum offer price rule. (See PJM MOPR Order Reversed; FERC Overstepped, Court Says.)

“I’m here to express my profound disappointment that we’re here today,” Murray said during the Advisory Committee meeting. He added that the RTO should do something about its lack of fast-start resources as winter approaches, particularly in MISO South.

Coalition of Midwest Power Producers CEO Mark Volpe said MISO’s proposed limits on outages may be punitive to generation owners. “We’re going way too fast here on something this serious,” Volpe said.

Jim Dauphinais, a consultant with Brubaker and Associates representing end-use customers, said the filing seeks to unnaturally force improved availability.

Imagining Blackouts

Board members who heard the discord urged stakeholders to work through their differences with MISO.

Director Baljit Dail asked stakeholders to imagine how they would respond today if the RTO experienced rolling blackouts. “How would you approach this problem differently? How would you change your answer?” he asked.

“I appreciate that no one wants rolling blackouts in the press … but I think there’s an unintended consequence here,” Madison Gas and Electric’s Megan Wisersky said. She said more rules for LMRs would drive some out of the market, resulting in reduced resources.

“I urge caution here,” she said.

However, representatives of the State Regulatory Authorities sector said they were supportive of a filing. Minnesota Public Utilities Commissioner Matt Schuerger said stakeholders cannot deny the urgency of needing changes.

Speaking at a Dec. 4 meeting of the board’s Markets Committee, MISO Executive Director of System Operations Renuka Chatterjee said “availability of resources is the key to avoiding real-time shortages.”

“We’re seeing an increase in unavailable megawatts for each of the last three winters,” Chatterjee told the committee.

Almost 12 GW (about 9%) of MISO resources are classified as LMRs, accessible only as part of emergency load management. The RTO had not called on LMRs for a decade after a localized Wisconsin emergency in February 2007 but has relied on them three times since 2017, most recently in MISO South in mid-September. Independent Market Monitor staffer Michael Wander said most MISO South LMRs were unable to respond in time during the September event because the units have long start-up times.

MISO has seen a 4.6-GW decrease in installed capacity from existing resources since 2017.

“We’ve experienced retirements of what we considered excess capacity,” RTO President Clair Moeller explained to board members.

Dail said the situation underscores the need for MISO to be able to better supervise planned outages. “This just looks like it’s going to get more complicated as we go forward,” he said.

Responding to a question from Director Barbara Krumsiek about whether MISO’s neighbors face similar availability challenges, Moeller said SPP has a similar experience of growing renewable resources paired with conventional generation retirements.

Seeking Clarity

MISO discussed a few recent additions to the possible multiple filings during the Dec. 7 conference call.

Staff said they propose to issue scheduling instructions up to 12 hours in advance based on resource lead times but would not actually call on the resource until two hours before it’s needed. Demand response resources that acknowledge scheduling instructions but are not ultimately called would nevertheless receive credit toward the five deployments per year that would be required of LMRs.

DR would also prove demand reduction capability by “performing to its requirements when called upon during the prior planning year” in addition to MISO’s original proposal of participating in a real power test. Testing of DR resources would begin for resource qualification in the 2020/21 planning year.

But stakeholders said the new demonstration option was vague, with some asking about the minimum number of performance hours and how MISO would account for performance when it calls up partial demand-reducing output.

MISO Director of Resource Adequacy Coordination Laura Rauch said the RTO’s testing requirements would require full output of a DR resource for at least an hour.

Xcel Energy’s Kari Hassler asked what would happen if a properly scheduled planned outage takes more time to complete under the original scope of work and an emergency event occurs during the outage extension.

Rauch said the outage extension would likely fall under MISO’s “high-risk” determination, and the outage could be rebranded as a forced outage for the time it overlaps a maximum generation emergency, which would count against a resource’s accreditation.

However, she also said MISO is still working through revisions of its proposed filings and may choose to delay the outage coordination piece until January, still targeting changes by the spring outage season. She said the RTO will accept another round of feedback through the end of the week. MISO is planning to post an updated version of its filing or filings by Wednesday and will use stakeholder feedback in final revisions.

[Editor’s Note: An earlier version of this story incorrectly identified Jim Dauphinais’ affiliation and misnamed the Coalition of MISO Transmission Customers.]