By Chris O’Malley

The Michigan Public Service Commission wants federal regulators to force MISO to turn over a study used to identify areas that require the operation of system support resources (SSR) in the state’s Upper Peninsula.

The load-shed study is “essential” to determining whether MISO’s analysis accurately identifies the local balancing authorities (LBA) that require the SSR units and — if not — how it should be modified to do so, the Michigan PSC said in a filing to the Federal Energy Regulatory Commission (ER14-2952).

In 2014, the Wisconsin Public Service Commission complained to FERC that Wisconsin ratepayers would pay a disproportionate share of SSR costs (ER14-2860, ER14-2862). FERC agreed, and MISO responded in September with revised rate schedules that shifted the costs of the Presque Isle, White Pine and Escanaba SSR units more heavily to Michigan.

Michigan regulators are protesting MISO’s allocation of SSR costs on the basis of the reduced LBA boundaries created by Wisconsin Electric Power Co. (WEPCo) as a result of Wisconsin’s challenge.

Michigan has argued that WEPCo’s LBA boundary changes “produce an unduly discriminatory and disproportionate allocation” of SSR costs.

As examples it cited Cloverland Electric Cooperative, whose SSR costs are estimated to rise by 800%, from $2.6 million to $21.9 million, and WEPCo’s load in the Michigan U.P., which the PSC says will increase by 1,000%, from $7 million to $70 million.

The Michigan PSC said it wants FERC to reject the use of WEPCo’s modified LBA boundaries to assign cost responsibility.

With the study data in hand, the PSC said, it could not only demonstrate the inaccuracy of MISO’s “optimal” load-shed study in identifying the load-serving entities that require SSR units, but also demonstrate the larger area of LSE loads that benefit from operation of the units at issue.

MISO’s Dec. 17 response to a FERC deficiency notice described the load-shed study as based on “optimal contingents” designed to “minimize” the volume of load identified as needing the SSR unit. “MISO admits that the impact area identified in the load-shed study ‘is not an all-inclusive identification of load that can reasonably be expected to benefit under every circumstance,’” the Michigan PSC wrote.

After reviewing the response, the PSC said it asked MISO for a copy of the unredacted load-shed study. MISO refused, the PSC said, saying it was only available to MISO staff and transmission owners.

“The Michigan PSC has reason to believe that the ‘optimal’ load-shed study does not accurately identify load that requires operation of the SSR units,” the PSC said. “For this reason, the Michigan PSC desires to conduct alternate studies that are designed to identify loads that require operation of the SSR units under more realistic conditions.”

Presque Isle Deal

Regardless of how the PSC’s request plays out at FERC, Michigan ratepayers may get some relief as a result of Upper Peninsula Power Co.’s agreement to purchase Wisconsin Energy’s Presque Isle generator. UPPCO said last month it would “step into” the existing rates but eliminate the SSR agreement, relieving U.P. ratepayers of its $97 million annual cost. (See Sale Would End SSR, Clear Way for WE-Integrys Deal.)