By Amanda Durish Cook

CARMEL, Ind. — MISO is seeking stakeholder feedback on its proposal to use a new calculation to crack down on generators that fail to follow dispatch instructions.

The proposed calculation, which comes after years of debate, will impose a “failure to follow dispatch” warning when a resource fails to move at least half its offered ramp rate over four consecutive dispatch intervals, MISO Market Quality Manager Jason Howard said during a Sept. 14 Market Subcommittee meeting. Generators are currently flagged after they deviate by more than 8% from dispatch instructions over four consecutive intervals.

MISO Executive Director of Market Design Jeff Bladen emphasized that the calculation is not yet final and asked for stakeholder suggestions.

After several months of delays, MISO said in May it was still developing software to support its effort to tighten tolerance bands on uninstructed deviations. The RTO’s Market Monitor has been recommending the project for more than five years. (See Monitor Again Criticizes MISO’s Uninstructed Deviation Rules.)

A MISO impact study using production data from May through July found that failure to follow dispatch increased from 2.4 to 6.1% under the new threshold. The study also found that the calculation reduced excessive and non-excessive energy charges by 4.4% across the MISO footprint for the three months, while Day-Ahead Margin Assistance Payment (DAMAP) disbursements decreased by 7.6% or $941,000.

MISO Market Monitor David Patton said the reduction in DAMAP payments is “huge” because it shows MISO will stop awarding make-whole payments to generators that fail to follow dispatch.

Howard said MISO now will seek feedback on the new calculation from the FERC Office of Enforcement and continue discussions with the Monitor’s staff. At an Advisory Committee meeting this spring, several stakeholders asked MISO to convene a workshop to discuss the RTO’s analysis and the possible shape of the proposal. (See “AC Prods Restart on Tighter Uninstructed Deviations,” MISO Advisory Committee Briefs.)

DTE Energy’s Nick Griffin asked if the new proposal might have “unintended consequences” by discouraging slow-ramping resources from offering in fear of being penalized.

“The goal here is to get people to offer the ramp rate that they are comfortable with and they actually can live with,” Bladen said. “We don’t want generators to offer a ramp rate that they can only meet half the time because the reality is we’re counting on the ramp. We’re counting on people to move.”

“It harms the system to provide a ramp rate that you can’t realistically meet,” Patton added. “Your offer parameters aren’t really accurate if you can’t perform to them.”

Some stakeholders expressed concern that the nearly $1 million in theoretically lost DAMAP would inordinately affect slower moving coal units.

“You’re talking about a million dollars [for] every generator [in] MISO. We’re not going to devastate anyone here,” Patton said. “There might be one or two units that are so inflexible that they might alter their offer, but that’s a good thing because we won’t be relying on flexibility that we really don’t have.”