CARMEL, Ind. — MISO will file a response to FERC’s recent deficiency letter on the RTO’s new constrained area category after an internal review, stakeholders learned on Thursday.
FERC issued the letter Sept. 6 (ER17-2097), inquiring about:
- What past outage information or expected future congestion estimates MISO plans to use to impose a dynamic narrowly constrained area designation;
- What conduct and impact thresholds MISO plans to use for mitigation;
- Whether dynamic narrowly constrained areas could also be simultaneously designated as simple narrowly constrained areas;
- Whether MISO’s existing binding reserve zone constraints would be used to apply mitigation measures
MISO Director of Market Evaluation and Design Dhiman Chatterjee said the RTO is working with its Independent Market Monitor to respond to the deficiency letter.
“We believe those are more clarifications [than changes] that they’re asking for. It’s a matter of providing more information, is our initial take on it,” Chatterjee said during a Sept. 14 Market Subcommittee meeting.
Under MISO’s proposal, filed July 14, dynamic narrowly constrained areas would address intense, short-lived congestion by allowing the Monitor to apply mitigation if the constraint has bound in 15% or more hours over at least five consecutive days. The definition would differ from FERC-defined narrowly constrained areas, which must bind for more than 500 hours annually. (See MISO Embraces Monitor’s New Constrained Area Category.)
The new category also would require the Monitor to have identified economic or physical withholding, or uneconomic production in the area. MISO proposed a $25/MWh “conduct threshold” for such determinations, meaning the behavior must have impacted LMPs or market clearing prices by at least that amount.
— Amanda Durish Cook
