MISO transmission customers filed a complaint with FERC last week that the grid operator should allow its customers to reduce their load without penalty to lessen the possibility of summer blackouts.

The Coalition of MISO Transmission Customers (CMTC) said in a filing that the load reductions will help address a 1.2-GW capacity shortage following MISO’s 2022-23 Planning Resource Auction for its Midwest subregion. The shortfall triggered a $236.66/MW-day cost of new generation entry clearing price for MISO Midwest. (See MISO’s 2022/23 Capacity Auction Lays Bare Shortfalls in Midwest.)

The RTO has said the capacity deficit might force it to order temporary, controlled load sheds this summer and it predicts insufficient firm resources to handle summer peak forecasts under typical demand. The grid operator’s management has also said members must build new generation or risk future blackouts.

CMTC argued that when the capacity auction fails to procure enough supply, it should allow some load to exit the system, bolstering reliability by trimming demand while also avoiding the steep capacity prices.

The group said it has members “actively assessing the need to reduce operations” by more than 200 MW at least through May 31, 2023.

“A significant factor in the customer’s operational decisions is the ability of the customer to avoid the PRA charges that it would otherwise incur,” CMTC told FERC.

The group argued that MISO’s tariff shouldn’t regard PRA charges as “unavoidable and sunk” for load. The group said the tariff is unjust and unreasonable because it doesn’t contain any options for load to leave the system when it faces threats to resource adequacy.

“Because the exit of the customer’s load and possibly other loads would provide reliability benefits to MISO as MISO addresses looming resource adequacy issues in its footprint and the shortage of capacity procured in the 2022/2023 PRA, load should have an opportunity to exit the system without being charged,” CMTC wrote. “MISO’s tariff should be revised to enable MISO to create an orderly process in which load could nominate to exit the MISO system for the remainder of the planning year, in exchange for avoiding PRA charges, to help MISO address the insufficiency.”

The group suggested that MISO could allow load exits equivalent to the 1.2-GW auction shortage and stop accepting any further load reductions once it resolves the supply and demand imbalance.

CMTC asked FERC for expedited treatment of its complaint, requesting a response no later than early July. It also said it had been in touch with MISO about its proposal before it filed the complaint.