By Amanda Durish Cook

CARMEL, Ind. — MISO will make two points in its comments to FERC in response to Energy Secretary Rick Perry’s proposal to allow “resilient” resources with a 90-day on-site supply of fuel to fully recover their costs. (See Perry Orders FERC Rescue of Nukes, Coal.)

The first point, according to Executive Director of Strategy Shawn McFarlane: The commission’s response to the Department of Energy’s Notice of Proposed Rulemaking should respect MISO’s existing reliability process that incorporates state rules.

The second: Any monetary value placed on resiliency must be supported by research.

“MISO and MISO states have a well-established process to address reliability and resource needs … and any approach needs to respect those regional processes, and even those regional differences,” McFarlane said at an Oct. 11 Resource Adequacy Subcommittee meeting.

He also noted that “MISO supports a thorough and complete process” for detailing reliability and resiliency attributes, and will urge a well-researched approach.

McFarlane said the 21-day public comment period didn’t provide enough time to collect stakeholder comments and summarize them in MISO’s comments, and he urged stakeholders to make individual filings.

MISO Executive Director of System Operations Renuka Chatterjee echoed McFarlane’s comments a day later at an Oct. 12 Market Subcommittee meeting.

“MISO and the states have well-established processes and initiatives in place to protect reliability,” she said.

MISO will seek a thorough FERC process and sufficient time for the RTO to review any final rule “so we can judge the applicability while respecting regional differences,” Chatterjee said.

“How about the 15-day implementation period?” joked Kevin Murray, attorney for the Coalition of Midwest Transmission Customers, referring to the NOPR provision requiring RTOs to make a compliance filing within 15 days of a proposed rule becoming final (RM18-1).

“I don’t know that 15 days would be sufficient, but all jokes aside, MISO will probably ask for more time to review and assess. Stakeholders that think the 15 days is too short should comment,” Chatterjee said.

MISO Independent Market Monitor David Patton confirmed that he would file comments.

“We’re going to file comments that stress the importance of being careful and reasonable when picking policies,” Patton said. “I don’t know that we understand what [resiliency] is unless it’s related to reliability.”

Patton said he could see the need for resiliency in planning for future contingencies but didn’t know if the concept should be monetized.

“Treating it as a separate idea and pursing it outside the market process is very harmful,” Patton said.