FERC: Further Compliance Filings for Entergy, MISO
FERC Accepts Entergy Compliance Filing, with Conditions
FERC directed further compliance filings from Entergy regarding its annual bandwidth filing and from MISO for Tariff revisions related to demand response.

FERC accepted Entergy’s compliance filing responding to a December ruling that found fault with the company’s accounting in its fourth annual bandwidth filing (ER10-1350). (See FERC Rules Against Entergy over ‘Bandwidth’ Accounting.)

The commission, however, found that it had “inadvertently” not included in its December order a requirement to calculate interest on refunds related to bandwidth payments. It asked Entergy to submit another compliance filing that recalculates interest, eliminates any refunds related to the sale/leaseback of its Waterford 3 nuclear plant and removes securitized asset accumulated deferred income tax (ADIT) and contra-securitized asset ADIT from the bandwidth calculation.

Entergy’s allocation of production costs among its half-dozen operating companies under its system agreement has been a source of continuing disagreement. Payments are made annually by Entergy’s low-cost operating companies to the highest-cost company in the system, using a “bandwidth” remedy that ensures no operating company has production costs more than 11% above or below the system average.

MISO Compliance Filings Still Contain Errors

FERC yet again sent proposed Tariff revisions related to demand response back to MISO for further clarification in two orders.

The first order addresses MISO’s Order 745 compliance filings addressing contradictory language in Tariff revisions that laid out a new cost allocation methodology for compensating DR resources (ER12-1266). FERC found that the RTO mostly complied with its directive to clarify its Tariff, but the commission found yet more inconsistencies within and between sections of its Tariff regarding compensation across zones, cost allocation between day-ahead and real-time market participants and the effective date for certain provisions.

FERC also found discrepancies between MISO’s compliance filings regarding Order 719 (ER12-1265). For example, the commission found that MISO used “megawatts” to express maximum daily regulation deployment in its August 2012 filing and “megawatt-hours” in its September 2013 filing. FERC also found that the RTO did not differentiate between consumption baselines for DR resources providing regulating reserves and those providing contingency reserves.

The commission directed MISO to submit compliance filings addressing its concerns in both dockets within 30 days.

— Tom Kleckner

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