By Amanda Durish Cook

CARMEL, Ind. — With less than a month remaining until MISO files Tariff changes to implement stricter requirements for outage notification, stakeholders last week offered alternatives that would soften the RTO’s proposal.

While talk at the Jan. 3 Reliability Subcommittee meeting was less contentious than in late 2018, several stakeholders still think MISO should file rules that are less punitive and allow for exemptions and more nuance in outage types. (See MISO, Stakeholders at Odds over Resource Availability Filings.)

The proposed outage rules represent the last piece of MISO’s short-term resource availability and need proposal, which has been divided into three FERC filings. While the RTO already made two filings that will require load-modifying resources (LMRs) to produce seasonal availability documentation (ER19-650) and subject demand response to annual capability testing (ER19-651), it has yet to file changes that will improve generator outage coordination, which it plans for no later than Jan. 31. (See “Stopgap Filings,” MISO to Address Growing Supply Shortage in New Year.) MISO hopes to implement the rules in time to cover at least part of the spring outage season.

The RTO has proposed that planned outages must be scheduled at least 120 days prior to the scheduled outage start date, avoiding “high risk” times. The plan would allow limited adjustments to an outage schedule — not to exceed seven days — 60 days prior to a start date. Planned outages scheduled or modified outside of those timeframes — and that occur during defined “high-risk” times where maximum generation conditions occur — would be categorized as forced outages, which count against a resource’s capacity accreditation. Resources would be allowed only one planned outage per 120-day period.

MISO has pledged to provide market participants with forecasts showing high-risk times on a subregional basis.

MISO Director of Resource Adequacy Coordination Laura Rauch said the goal of the filing is to encourage more forward scheduling of outages so the RTO can better prepare for any reliability risks.

But some stakeholders say that MISO’s forecasts are not accurate enough to define such periods of high risk to the system. They also contend that MISO should better define high-risk predictions, outage reporting requirements and penalties.

“I won’t pretend that we have unanimous consensus on this,” Rauch said.

Rauch said MISO will continue to work on how it can improve its Maintenance Margin, a nonpublic member webpage that keeps a forward account of how many megawatts can be taken out of service without affecting reliability.

Rauch said MISO is now focusing on whether it should provide incentives for generators that willingly move outages to improve reliability at the RTO’s request. MISO is also examining how it can best collect information to gauge how flexible a certain generator’s outage might be.

Exemptions and Outage Distinctions

DTE Energy submitted an alternate proposal that would allow a distinction between advance notice planned outages and short-term maintenance outages, which last two weeks or less and are more minor in nature and more flexible than periodic planned outages.

DTE also recommends that MISO under some circumstances exempt resources from a forced outage penalty for outages that occur during capacity emergency conditions. One exemption would permit resources to schedule planned outages even during high-risk periods if they provide four months’ notice; the other would allow for short-term maintenance outages scheduled at least seven days in advance and “entirely above” a MISO-defined scheduling margin, which would rely on a version of the Maintenance Margin process.

Xcel Energy’s Kari Hassler said her company supports DTE’s suggested tiered approach with exemptions and added that MISO should allow outages to be scheduled according to availability shown on the Maintenance Margin. She said a resource qualifying for an exemption should be allowed to revise outage stop and start times and durations “at any time as long as the shift maintains or improves the Maintenance Margin.”

Hassler also contended that MISO should allow more than one planned outage per 120-day period if the outages are taken for different reasons, saying a small testing outage can portend a major planned outage. She also urged MISO to have more faith in the motivations of generation operators.

“I think for the most part, generator owners and operators want to do the right thing. They want to schedule outages during low-risk periods. Generator owners and operators are not gaming the system. They want to get this right just as much as MISO does,” Hassler said.

Ameren’s Jeff Moore said although his company supports MISO’s push for better outage coordination and transparency, the proposal should contain some allowances for shorter-term maintenance outages.

“We do have to have this to properly maintain our assets,” he said.

Moore noted there are “legitimate reasons” for having more than one outage in a four-month timeframe and that resources should not be penalized for adjusting the timing of major planned outages as long as there is adequate headroom in the Maintenance Margin.

Several stakeholders also offered the idea that MISO delay a Tariff filing altogether in favor of providing market participants with more upcoming outage data and high-risk period predictions. They said MISO might see a natural improvement in outage coordination as generation operators gain more access to forward-looking data.

“Let’s see how this works for a year. If it works well, we may not need penalties. Nobody is suggesting that generation owners have been playing games up until now,” said Bill Booth of the Mississippi Public Service Commission.

Rauch responded that MISO has been furnishing the Maintenance Margin tool for several years, but it remains underused. She also said the RTO still needs more information about generator owners’ outage plans to manage increasing emergency conditions.

Rauch said MISO staff will scrutinize its proposed notification times and rescheduling requirements and modify the proposal over the next week. The RTO has planned a conference call to review final Tariff language with stakeholders on Jan. 14.