MISO: No Choice but to Double Up on 841 Compliance
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MISO said FERC's refusal to grant a delay on Order 841 compliance means it must roll out a storage participation model twice on old and new market platforms.

MISO is priming its aging market system platform to host energy storage offers by mid-2022 but still warns that compliance with FERC Order 841 poses a risk to the market system’s replacement.

FERC in July issued without comment a second refusal to give MISO until 2025 to fully bring storage into its markets under Order 841 (ER19-465-005). The RTO had sought rehearing on the commission’s first extension denial. (See FERC Rejects MISO Request for 2nd Order 841 Delay.)

The grid operator still argues that its June 6, 2022, compliance deadline will postpone the launch of a $145-million overhaul of its market platform because the software will have to twice build a storage participation model.

Jeff Bladen, MISO’s executive director of digital strategy, told stakeholders Thursday that staff will try their best to launch a storage participation model alongside the new market platform.

“We’re doing everything we can to accelerate it based on stakeholder ask,” Bladen said during a Market Subcommittee teleconference. “We want all these deferred market products online sooner rather than later.”

Bladen warned that MISO will be building a participation model twice on two separate platforms.

“We are full steam ahead to build the storage model twice — once on the legacy system and again on the new system,” he said. “Right now, we see us on schedule, and we’re doing everything we can to get the electric storage resource launched by the [second quarter] of next year.”

MISO is slated to migrate to its new market platform in late 2024 or 2025, but Bladen said building the energy storage participation model twice might threaten that timeline.

He said the RTO “could not uncover, after many months of exploring,” any way around two full software builds of the participation plan.

Clean Grid Alliance’s Natalie McIntire thanked MISO for sticking to its original timeline after FERC’s second rejection.

“There are, I believe, at least 7,500 MW of energy storage in the MISO interconnection queue,” McIntire pointed out.

She said one reason storage development has faltered in the grid operator’s footprint is because storage owners lack “robust” participation rules and clear financial incentives to bring storage to market.

“In my mind, it’s sort of a chicken and egg problem,” McIntire said. “Once this market model and Order 841 compliance is complete, you’re going to see a lot more of it. Just because you don’t see it now, doesn’t mean there’s not a lot of it behind the dam.”

Staff is still pondering how a storage asset designated to solve transmission issues can also provide market services. That work is separate from Order 841 compliance.

MISO adviser Michael Robinson drew parallels between storage functioning in both the markets and transmission realms to an exchange between Alice and Humpty Dumpty in Lewis Carroll’s “Through the Looking Glass.”

“When I use a word, it means just what I choose it to mean — neither more nor less,” he said, quoting Humpty Dumpty. He added Alice’s reply: “The question is whether you can make words mean so many different things.”

Robinson said storage as transmission assets will probably wait before being called on for transmission purposes. “They could sit idle a long time, so let’s enhance the value-stacking,” he said.

Storage serving as transmission assets must enter the interconnection queue before participating in the markets, Robinson said. He also said storage assets, when charging, will be affecting locational marginal prices and the energy imbalance.

MISO is also drafting a workplan on how it will redefine its markets to manage a changing resource mix and more intense weather. (See MISO Begins Pondering Future Market Changes.)

“The idea is to be able to articulate and describe the needs of the system,” Senior Manager of Policy Studies Jordan Bakke said.

Bakke said the RTO will produce a report on evolving market needs by the end of the year.

Energy MarketFERC & FederalMISO Market Subcommittee (MSC)Public Policy

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