By Amanda Durish Cook

FERC on Tuesday approved a MISO proposal requiring owners of load-modifying resources to provide firmer and more clearly documented commitments regarding their availability before participating in the RTO’s capacity market.

The proposal represents the first piece of MISO’s three-part near-term resource availability and need initiative.

” … Recent maximum generation emergency events have frequently occurred outside the summer season as generator forced outages and high load conditions converge with planned generator outages that are typically scheduled in the spring and fall seasons. MISO contends that these spring and fall maximum generation emergency events do not align well with the obligations of LMRs, which currently are not required to serve MISO load in non-summer seasons,” the RTO said in making the case for the new rules.

The new rules require a load-modifying resource (LMR) to offer capacity in accordance with a seasonal availability report provided to MISO and commit to deploying based on the shortest notification time it “can consistently meet” but no longer than 12 hours (ER19-650). LMR owners must provide that information to MISO during registration.

In return, MISO will issue scheduling instructions before an emergency occurs based on an LMR’s unique notification times. The RTO has also promised to confirm or withdraw advanced scheduling instructions at least two hours prior to an expected emergency event. LMRs that acknowledge scheduling instructions will receive credit for one of the five times per year that LMRs are required to respond, regardless of whether the emergency declaration is made.

MISO said the rules will improve transparency around LMR capability and give it easier access to LMRs during emergency situations.

In approving the filing, FERC also granted a waiver of MISO’s usual deadlines for LMRs to register their availability for the April capacity auction. LMRs now have until March 1 to complete registration. (See “LMR Registration Confusion” in MISO Preliminary PRA Data up Slightly from Early Prediction.)

A group of MISO industrial customers protested the filing, saying the RTO was vague and failed to outline how the “best physical capability” and “shortest notice requirements” of LMRs would be measured and verified. Those customers also said the new availability requirements could create an “incentive for LMRs to exit the market,” which could drive up capacity auction clearing prices.

But FERC said cut-and-dried availability rules wouldn’t work best for LMRs, which differ in operating characteristics and limitations: “Although a specific definition would provide certainty to some LMRs, it would likely be incompatible with the capabilities and circumstances of other LMRs. Therefore, we find reasonable MISO’s proposal to give flexibility to each LMR in determining its own capabilities and the type of supporting documentation it can provide for the purpose of demonstrating its capabilities.” The commission also dismissed as “speculative” the claim that the RTO’s proposal will force LMRs to exit the market.

MISO has two other near-term filings awaiting FERC action as part of the short-term resource availability and need project: one to subject demand response to annual capability testing and the other to impose new generator accreditation penalties for planned outages taken fewer than 120 days in advance and during what MISO deems “low-margin, high-risk periods.” The trio of filings is aimed at immediate relief in time for spring and to buy time for in-depth solutions. The Market Subcommittee and Resource Adequacy Subcommittee will work on the more involved solutions — yet unnamed — through 2020. (See Stakeholders Seek Slowdown on MISO RAN Project.)