MISO is considering whether the transfer limit of 876 MW between MISO South and MISO North used in this year’s Planning Resource Auction should be adjusted for the 2017/18 capacity auction and if resources supplying the capacity will be delivered on a firm or non-firm basis.

MISO posed several questions to stakeholders at the Aug. 3 Resource Adequacy Subcommittee (RASC) meeting:

• Should the starting limit for the sub-regional power balance constraint (SRPBC) prior to accounting for firm transmission service be 2,500 MW or 1,000 MW?
• In treating firm transmission service sold across the contract path, should SPP:
• Differentiate for firm transmission that is or is not associated with a capacity sale in another market?
• Consider the ability of a transmission customer to redirect transmission service (i.e., redirect sink from PJM to MISO North)?
• Treat pseudo-tied resources differently?

Under MISO’s settlement with SPP over the use of its transmission system, flows between the North and South regions are considered non-firm. The agreement “explicitly did not provide firm contract path or firm flow entitlements,” according to MISO.

MISO’s 2016/17 PRA enforced a limit of 876 MW for South-to-North transfers. The initial limit of 2,500 MW was downgraded to 876 MW after MISO subtracted firm exporting reservations that had completed a feasibility analysis.

“We’re trying to achieve an efficient but reliable PRA outcome,” explained Kevin Sherd, MISO director of forward operations planning. “If we approve 2,500 MW and can only get 500 MW delivered due to congestion, that’s a problem. The higher the number goes from South to North or Zone 1 to Zone 6,” the higher the risk, he said.

“I’m not arguing one or the other today. I’m teeing this up for a September discussion,” Sherd said.

Currently MISO allows two opportunities for resources to participate in the PRA as firm capacity: as a network resource interconnection service (NRIS) or as an energy resource interconnection service (ERIS) with a firm point-to-point transmission reservation.

MISO Manager of Resource Adequacy Coordination Laura Rauch said the RTO completes an annual deliverability test on NRIS generators to make sure they are able to deliver power to network load. ERIS generators are analyzed via an annual long-term transmission rights feasibility test and through the expansion planning process.

ITC Holdings’ Ray Kershaw suggested that opening up participation for generators without firm rights might allow some non-firm external generators to participate in the PRA. “You’re opening up a whole lot here,” Kershaw said.

Dynegy’s Mark Volpe asked if MISO could use data from this summer to establish anticipated power flow needs to make a more educated decision.

Sherd said multiple days this summer could provide data for an estimated transfer limit and said MISO would bring numbers back to the next RASC meeting.

Other stakeholders asked what the Independent Market Monitor thought of changing the transfer limit.

IMM staffer Michael Chiasson said the Monitor will review MISO’s questions but declined to comment on the transfer limit. The Monitor’s State of the Market report recommended improving the modeling on transfers by introducing a derating factor representing the probability that MISO neighbors will request a reduction from the 2,500-MW transfer limit because of an emergency. (See Monitor’s State of the Market Report Seeks Changes to MISO ELMP.)

Stakeholder input on the matter is requested before the Aug. 31-Sept. 1 RASC meeting. MISO hopes to adopt a solution for the 2017/18 PRA.

MISO Inserting More Deadlines into PRA Timeline

MISO wants more official deadlines for market participants worked into the PRA timeline, Manager of Resource Adequacy John Harmon said.

The RTO is proposing to attach explicit due dates to multiple data submittals made before the auction, including quarterly Generating Availability Data System figures, annual output data for run-of-river and biomass resources, load forecast revisions after Nov. 1 and the unforced capacity value confirmation.

“These [requirements] aren’t new, but we’ve never had definitive dates. No new action is required … but a lot of market participants said, ‘I didn’t know you needed this by this date,’” Harmon said. “We had trouble during the last auction working with folks to make sure deadlines were met.”

The RTO will also attach consequences to missed deadlines, Harmon said, but not before MISO Client Relations reaches out to market participants about delinquent information. After that, MISO will process late submissions in monthly “batches” rather than on an individual basis and could deny requests for late submissions altogether, possibly disqualifying the market participant from offering in the PRA.

Harmon said MISO is also striking the deadline for the Monitor to deliver default technology-specific avoidable costs, as those reference levels will become static in upcoming auctions. (See MISO Moves Forward on Auction Design; Seasonal Filing Delayed Again.)

New deadlines aren’t yet finalized. Harmon said MISO would post a new PRA timeline with additional deadlines next month.

— Amanda Durish Cook