By Amanda Durish Cook

CARMEL, Ind. — WEC Energy Group uncovered a Tariff inconsistency while it was developing a proposal to improve MISO’s behind-the-meter generation participation rules, a company representative said last week.

WEC’s Chris Plante said MISO’s definition of what constitutes a network resource, defined in Module B of the Tariff, doesn’t recognize all capacity acquired under Module E, which covers the procurement of resource adequacy (RA).

Module B does not allow a network customer to generically claim the MISO energy market or capacity market as its network resource, thus technically excluding the customer from counting unregistered BTM generation — which does not have existing transmission service — toward RA requirements, Plante said during an Oct. 11 Resource Adequacy Subcommittee meeting. However, Module E currently allows those resources to be counted as capacity.

To reconcile the discrepancy, Plante suggested that MISO’s definition of “uppercase,” or registered, BTM generation be limited to the following categories:

• Network resources behind the market delivery point;
• Resources behind the market delivery point participating in the market; and
• Resources behind the market delivery point that causes flow on the transmission system.

Plante proposed that any resource be required to register as a network resource with MISO before it can fulfill capacity obligations. The proposal aligns with a plan the RTO is already formulating through planned implementation of a one-time deliverability test for BTM generators that could trigger a requirement to acquire network service in an upcoming capacity auction. (See MISO Proposes Deliverability Rules for Behind-the-Meter Capacity.) Unregistered BTM generators currently enjoy identical treatment to those generators registered as a network resource without having to register with MISO, something the RTO aims to change.

Plante said MISO’s “lowercase” BTM generation — resources not required to register — should be limited to those resources located behind the retail meter and used by a retail customer only to manage load “at the same electrical location,” Plante said. Such resources would not have to respond to emergency conditions.

“We just want comparable treatment among all network resources,” Plante said. “We don’t believe just listing the MISO market as your network resource is appropriate,” according to Module B of the Tariff, Plante said.

Customized Energy Solutions’ Ted Kuhn asked if network customers would now have to enter the capacity auction with a resource already specified. “There would be no way to just go to the auction and say, ‘I’ll take what’s available,’” Kuhn said.

Kevin Murray, attorney for the Coalition of Midwest Transmission Customers, agreed that network customers aren’t currently following MISO’s Tariff as written but added that if they did, and had to identify resources before participating, the capacity auction would clear at near-zero prices “until the end of time.” Plante agreed.

Other stakeholders suggested it was time to re-examine Module B and update its network resource definitions to align with today’s emerging technology.

Plante said WEC wasn’t “wedded” to its proposal and asked stakeholders for more written feedback on the two types of BTM generation.

“This uppercase and lowercase BTMG personally drives me nuts,” said Planning Advisory Committee Chair Cynthia Crane during a Sept. 27 meeting of her committee. She suggested MISO instead use an “R” before the BTMG acronym to differentiate registered and unregistered BTM generation, instead of using the “uppercase” and “lowercase” designations.

MISO will continue to discuss market definitions for BTM generation at the November RASC meeting. Earlier this year, Manager of Resource Adequacy John Harmon said he thinks the energy industry will be focusing on BTM and distributed energy resource issues for years to come.