By Amanda Durish Cook

CARMEL, Ind. — In a shift opposed by some stakeholders, MISO has adopted the Independent Market Monitor’s recommendation to base pricing of external capacity resources on bordering balancing authorities.

MISO is now proposing a single clearing price for resources based on balancing authority in upcoming Planning Resource Auctions. For external resource zones adjacent to MISO Midwest and MISO South, the RTO plans to use historic shift factors based on energy flows to produce a blended price, Laura Rauch, manager of resource adequacy coordination, said during a June 7 Resource Adequacy Subcommittee meeting.

MISO’s original proposal for implementing external resource zones would have set prices based on geographic groupings of external generation regardless of balancing authority. (See “IMM Offers Own PRA External Zone Design,” MISO Resource Adequacy Subcommittee Briefs.)

Reliability Concern

Rauch said MISO wants to prevent reliability problems over the RTO’s growing reliance on external resources. The RTO says external resources, which averaged about 5,000 MW for planning years 2015/16 through 2017/18, could increase by more than 2,600 MW “in upcoming years.”

“It’s not too large of a concern right now because they are spread out throughout the footprint, but in the coming years, they are expected to [increase],” Rauch said.

Last month, Michael Chiasson of IMM Potomac Economics said MISO’s original proposal would mean that two external resources located in different balancing authorities could be lumped into the same external zone. He argued that preserving balancing authority borders would make for more efficient pricing.

A MISO analysis showed that the Monitor’s proposal would have resulted in prices ranging from $6.63/MW-day in MISO Midwest’s Zones 1-3 and 5-7 for the 2015/16 PRA (versus an actual $3.48/MW-day) and $3/MW-day in MISO South’s Zones 8 and 9 (versus $3.29 actual). The Monitor proposals would not change the $150/MW-day clearing price in Illinois’ Zone 4.

Stakeholder Opposition

Not all stakeholders are sold on the Monitor’s pricing plan.

WPPI Energy’s Steve Leovy and MidAmerican Energy’s Greg Schaefer said the proposal would treat far-flung resources the same as resources close to MISO. “It strikes us as counter-intuitive, at least initially. It seems odd to us that you call this a locational proposal but you really don’t care about the location of resources,” Schaefer said.

Rauch said the concern is “not so much where an external resource is located in a neighboring balancing authority than how a resource impacts the MISO footprint.”

NRG Energy’s Tia Elliott said her company also opposes the creation of external zones and instead wants the RTO to require firm transmission to both its border and to the sink.

Rauch said resources that MISO designates as “electrically equivalent” will continue to count toward local credit as internal resources do. Some stakeholders have balked at that approach, saying it amounts to special treatment of external zones.

Last month, Consumers Energy’s Jeff Beattie said external resources should come in second to MISO resources, as the latter are factored into the Transmission Expansion Plan. MISO also ensures deliverability, while deliverability from external zones, even with firm service, is not certain, Beattie said. “Resources in the MISO footprint do receive preferential treatment, as they should,” he said.

Dynegy’s Mark Volpe said his company supports creating external zones. “We’ve always thought that an external resource counting toward the [local clearing requirement] is inconsistent when MISO does not have dispatch control over the external resource,” Volpe said.

Motion to Halt Proposal

Customized Energy Solutions’ David Sapper, representing the Load-Serving Entities sector, said MISO should simply prohibit external resources from counting toward local clearing requirements. The RTO would conduct a pre-auction check of external capacity that intends to offer to see if any are pivotal suppliers; if there are pivotal suppliers, it would have to institute new mitigation measures, Sapper said.

“We understand that reliability issues have been raised; whether that amounts to a concern or not remains to be seen,” he said.

Sapper submitted an LSE motion that called for MISO to file a capacity transfer rights proposal that would treat long-term supply arrangements involving external resources the same as internal planning resources. The RTO would delay creating any external resource zones until FERC’s final action on the filing. The motion went to an email vote that will be tallied late next week.

“As stakeholders have already noted in RASC discussions, it is impossible for LSEs to fully assess the risks of MISO’s proposal for changing the treatment of [external resources] without having certainty about the rules for the distribution of excess PRA revenue,” the motion said. It said a capacity transfer rights filing is the “proper starting point for any discussions about changing the treatment” of external resources.

“Let’s take up the hedge proposal first and wait for a FERC decision,” Sapper urged stakeholders.

RASC liaison Shawn McFarlane said waiting for final action by FERC could prevent the RTO from heading off reliability problems with the increasing amount of external capacity. Dynegy’s Volpe said it could be as late as 2025 before petitions for rehearing are resolved.

“I look forward to the day where these external resources that pose a threat to reliability one day join the MISO footprint,” Sapper said. “I think footprint growth or changes have really called into question some of these concerns.”

Beattie said Consumers has always disagreed with external resources counting toward local clearing requirements. “Local is the key word here,” he said, prompting laughs among the stakeholders. “There is more fuel diversity taking place and there are a number of plant retirements occurring. … If MISO doesn’t have control of these external resources through pseudo-tying or something else, then this new rule is worthless,” Beattie said of MISO’s revised proposal.

MISO plans to alter auction hedging under the external zones, using historical considerations to distribute excess auction revenue to shield some prioritized generators against price separation.

The first in line for excess revenues would be 500 MW of external and internal generation that opted out of the energy market when it was formed. Second would be 4,600 MW of market arrangements made before the capacity market was created, assuming their grandmothered agreements are still valid. Almost 2,800 MW of generation that signed contracts with load before MISO changed zonal boundaries in 2011 would be third in line for revenue distribution for a temporary, seven-year period.

MISO plans to file its proposal with FERC in early fall in order to introduce external zones in the 2018/19 PRA. The RTO will accept feedback on its proposal until June 21 and present any revised proposals at upcoming RASC meetings.