By Amanda Durish Cook

After five years of discussion, MISO and PJM are still slogging through development of an alternative to their “freeze date” used to grandfather permissible unscheduled transmission flows that predated their seam.

And while the RTOs promise progress on the issue, they acknowledge that outside entities with a stake in any changes are still resistant to a proposed solution, stakeholders learned Tuesday.

The RTOs rely on the April 1, 2004, “freeze date” to determine firm rights on flowgates based on historical firm flows that occurred before creation of the seam between their markets. That date is used to establish acceptable flows in both the market-to-market (M2M) process and transmission loading relief.

Andy Witmeier, of MISO’s seams administration team, said the RTOs still agree that the freeze date needs updating.

“We’re more than 15 years away from it now, and issues with the date have become prominent,” Witmeier told stakeholders during a MISO-PJM Joint and Common Market conference call. Those issues primarily have to do with how designated network resources are dispatched and determining eligibility for transmission service requests.

But five years on, the RTOs are still facing opposition from parties to their congestion management process (CMP), which includes MISO, PJM, SPP, the Tennessee Valley Authority, Manitoba Hydro, the Minnkota Power Cooperative and Associated Electric Cooperative Inc. The CMP was established to minimize unscheduled market — or loop — flows among neighboring balancing areas.

All CMP parties stand to be affected by a change in the freeze date, MISO staff have said.

In November, MISO and PJM announced that their original goal of a full freeze date replacement by June 2019 was too optimistic. Now, the RTOs say they will continue talks on a possible replacement throughout the year and hope to implement a solution in 2020.

FFE vs. FFL

In M2M procedures between RTOs, an RTO’s entitled firm usage is classified as a firm flow entitlement (FFE). In the transmission loading relief process utilized for nonmarket entities in the CMP, an RTO’s entitled firm usage is classified as a firm flow limit (FFL).

Witmeier said MISO and PJM were close to a solution last year, but that nonmarket entities party to the CMP had issues with how the proposal might impact FFLs.

The RTOs’ proposal would divide flowgate allocation — or FFEs — among four separate “buckets” to prioritize access to the flowgates. (See “Freeze Date Update,” MISO-PJM Markets Meeting Addresses Seams Issues.)

The first bucket — which would get primary consideration for flowgate needs — would consist of active designated network resources predating the freeze date and historic transmission service requests.

A second bucket would consist of active designated network resources dating after the freeze date, while a third would be used for transfers from local balancing authorities with excess generation to LBAs short on generation.

The fourth, lowest-priority bucket would be for market-wide transfers based on RTO transmission planning.

MISO and PJM last summer changed their policies to make post-freeze date designated network resources with a defined dispatch order eligible to receive FFE allocations — a small piece of the RTOs’ broader proposed solution.

Witmeier said most CMP entities favor completing an FFE solution by mid-2020 while continuing to work on how FFLs would be handled. However, some want any solution delayed until both FFEs and FFLs can be addressed.

“Obviously, we have to have a unanimous agreement from all parties. … We’re not there yet,” Witmeier said.

‘A Long Time’

MISO, PJM and CMP entities have been working for about five years on a freeze date alternative through their Congestion Management Process Working Group.

Witmeier also said the two RTOs are specifically working on how to account for FFE allocation priorities and in what order they would curtail the overallocation of rights on a particular flowgate.

A joint white paper on the matter that would detail an alternative way to calculate the freeze date is still in the works, Witmeier added.

Customized Energy Solutions’ David Sapper asked if MISO and PJM could move to a FERC filing on a freeze date alternative without all nonmarket entities signing on.

“Five years is a long time,” Sapper observed.

PJM Director of Energy Market Operations Tim Horger said the two RTOs are considering substitutes to unanimous accord and may consider a filing that not all parties have signed on to. He also said parties to the CMP are “frustrated” that talks on a potential solution have taken this long.

“There is going to be a path forward shortly,” Horger promised stakeholders.

MISO and PJM staff promised to return to the Aug. 27 JCM meeting with an update.