FERC has greenlit MISO’s plan to require its demand response to make real-world demand reductions to fulfill the RTO’s testing requirements.
FERC said the “modifications more clearly define and standardize the existing testing procedures” in a Nov. 17 order (ER25-2845).
MISO now can mandate DR to make actual megawatt reductions for testing instead of submitting mock tests to prove capability. MISO worked on the proposal over 2025. (See MISO Tries to Ward Off DR Fraud with New Testing Regime.)
“[W]e find that establishing stricter testing waiver criteria and adding specific testing parameters for demand resources in the tariff will provide greater certainty that demand resources will be available when called on by MISO,” FERC said, adding that the rules should diminish the “likelihood of market participants registering resources into the auction in a manner that does not accurately reflect the true capability of their resources.”
The commission granted MISO’s requested effective date of July 15, 2025, so the new testing regime is in place by the 2026/27 capacity auction. It said it weighed the quick turnaround time against the importance of accurate testing. It pointed out that MISO allows market participants to use “operational data gathered in the ordinary course of business” to prove full demand reduction or allows resource owners to defer testing until May 29, 2026.
MISO has about 15 GW of DR as of late 2025. But MISO has said its experience shows that only about half of the DR fleet is available when needed.
Under the new MISO paradigm, DR resource owners must demonstrate they can honor their notification time while dropping demand within the time-of-day periods that match with hours that MISO expects system risk to occur. The resources must hold their demand reduction for 15 minutes, covering at least two meter intervals. Owners must show a full reduction of all the megawatts they specified in registration during a real power test. MISO said it would allow some resources that experience a weather impact during testing to demonstrate a bit less than their full stated capability.
MISO will allow select DR owners to proceed with a mock test if a state authority expressly allows it or if it’s a proven resource that has responded to a call in the past three years and has not changed its specifications since.
DR and distributed energy resource aggregators argued before FERC that MISO’s plan allows discriminatory treatment between load-serving entities’ DR programs and aggregators of retail customers.
Voltus and Advanced Energy United said MISO’s testing waivers for load-serving entities’ DR programs amounted to aggregators’ DR groupings being held to a different standard. The RTO included testing waivers for retail DR programs overseen by state regulatory authorities. It didn’t extend the possibility of waivers to aggregators.
FERC said the testing exceptions aren’t discriminatory and recognize “states’ interest and expertise in ensuring that the demand response programs under their jurisdiction are effective.” The commission further pointed out that MISO’s tariff already contains the potential for testing exemptions for retail programs managed by state regulators. It said it was “reasonable for MISO’s testing requirements to account for relevant testing provisions in retail programs.”
The testing rules are part of a myriad of new restrictions MISO has placed on its DR since the RTO, its Independent Market Monitor and FERC staff discovered multiple instances of fraud, misrepresentation or rule violations among its DR fleet. (See MISO Tries to Clear Up Assortment of New DR Rules.)
