By Amanda Durish Cook
MISO and PJM could terminate or suspend pseudo-ties that no longer satisfy agreed-upon requirements under a joint proposal.
The RTOs’ proposal also includes a provision that would make each of them the native reliability coordinator for units pseudo-tied into the other balancing authority area, “responsible for transmission-related congestion on the transmission system where the pseudo-tied units are physically connected.”
The RTOs are adding coordinated pseudo-tie policies to their joint operating agreement. MISO last week released a first draft for stakeholder review.
The proposed rules also stipulate that pseudo-tied units must follow both PJM and MISO modeling procedures and obtain station service according to native balancing authority rules. They also make clear that pseudo-tied units committed as capacity resources in a delivery year cannot be directed to serve load in the native balancing authority when the attaining balancing authority requires the unit’s output — unless they are needed to avoid exceeding NERC operating limits in the native balancing authority. The RTOs also agree that only pseudo-tied units — and not the RTOs — are responsible for compensating an attaining balancing authority for failure to deliver energy.
“There were some common-sense coordination practices to add to the joint operating agreement,” MISO Senior Director of Regional Operations David Zwergel said during a June 29 Reliability Subcommittee call. He said MISO and PJM staff collaborated to come up with the proposed rules.
Zwergel said the RTOs expect to file the agreement changes with FERC in late July and asked stakeholders to submit written comments on the draft language by July 13. PJM is also reviewing the language with its own stakeholders, he noted.
The joint effort stems from two FERC deficiency letters in response to the RTOs’ separate attempts to implement more stringent rules in order to improve control over an increasing number of pseudo-ties between MISO and PJM. The letters asked both MISO and PJM to explain efforts they undertook to work with each other in developing the rules. (See MISO, PJM to Try Again on FERC Pseudo-Tie Filings.)
Both RTOs have said they plan to refile different versions of the stricter pseudo-tie rules. MISO initially said that adding standard pseudo-tie rules in the RTOs’ joint operating agreement was unnecessary but changed course earlier this year. It also recently asked FERC to schedule a technical conference to clarify the rules governing the implementation and use of pseudo-ties. (See MISO Asks FERC for Pseudo-Tie Technical Conference.)
During last week’s call, Entergy’s Jennifer Amerkhail asked why the RTOs also included rules governing “partial” pseudo-ties — an arrangement that accommodates generators that supply both RTOs.
Zwergel responded that earlier this year a MISO partial pseudo-tied resource failed to follow dispatch orders and overproduced on one side of the seam. The proposed rules expressly state that the portion of the generation dedicated to supplying the attaining balancing authority must follow its instructions, while the remaining generation must follow native balancing authority rules and dispatch.
Other stakeholders asked why the RTOs would include a requirement for 42-month written notice in advance of terminating a pseudo-tie.
Zwergel said the requirement is based on a six-month advance in addition to PJM’s three-year forward capacity auction. While the notice is unnecessarily long for MISO, it is necessary to accommodate the RTOs’ disparate capacity auction schedules, he said.
