By Amanda Durish Cook
MISO stakeholders say they do not expect perfect procedures at the seams with neighboring balancing areas, but they do want the
RTO to implement reforms to address price deviations, remove obstacles to interregional transmission projects and improve cost allocation among those projects.
Seams issues were the “hot topic” at last week’s Advisory Committee discussion moderated by consultant Robert Gee.
Remove ‘Triple Hurdle’
Several times during last week’s discussion, stakeholders called for removal of the “triple hurdle” faced by interregional projects, which must meet a specific interregional cost-benefit standard as well as comply with the internal standards of the two RTOs involved.
Stakeholders also repeated a request that MISO and SPP lower the minimum 345-kV requirement for interregional projects. In comments filed ahead of the meeting, the Power Marketer sector noted that of the 300 interconnections between the two RTOs, only 12 meet that standard.
The Competitive Transmission Developer sector recommended that MISO create a new interregional project category with a separate, singular benefit calculation. “MISO should conduct outreach to neighboring regions to advocate for adoption of the proposed interregional criteria in both [joint operating agreements] and in MISO’s regional Tariff as a separate project category,” the sector wrote.
It noted that RTO boundaries are “artificially imposed and do not reflect natural barriers to the flow of power throughout the region.”
The Environmental Sector urged MISO and PJM to expedite their initiative on targeted market efficiency projects, formerly called “quick hit” projects. The sector also urged MISO to resolve disagreements with other RTOs over the future scenarios that should be studied.
Letting Go
The Independent Power Producers sector predicted a dire future for MISO’s market if the RTO failed to improve its market-to-market locational energy pricing and settlements.
The IPPs said MISO’s “uncompetitive” capacity construct and abundant wind resources would incentivize energy exports. The sector criticized MISO and its Independent Market Monitor for endorsing concepts rejected by other RTOs, such as the proposed two-season capacity construct. It also criticized MISO’s efforts to discourage generators from exporting power under pseudo-tie arrangements with PJM. (See MISO Delays Seasonal, Locational Capacity Constructs.)
“MISO staff and the MISO IMM seem to have a hard time letting go of some of their proposals that have been evaluated and subsequently rejected by their seams partners and their seams partners’ constituents and stakeholders,” the IPPs said.
The Public Consumer sector declined to recommend specific changes but observed that “transmission from region to region … is a major way that [operational] efficiency across seams can be realized.”
The Transmission Dependent Utilities sector said RTOs should improve data exchange to better coordinate outages and update firm flow entitlement calculations. “As additional flowgates are determined to be significantly impacted by the dispatch in neighboring regions and interregional transactions, the modeling detail of neighboring systems must expand,” the sector wrote.
The TDUs also said RTOs should “seek middle ground rather than holding out for the ideal solution” and consider mediating seams issues when necessary.
Chris Plante, of TDU member Wisconsin Public Service, said the best way to improve the efficiency of the seam is to operate seams dispatch from two RTOs as if they were “under a single commitment and dispatch algorithm.”
The Transmission Owners sector wrote in favor of coordinating congestion hedges with other RTOs, improving real-time coordination with SPP and altering generator pseudo-tie requirements to synch with PJM’s market.
MISO Board: Cooperation is Key
MISO officials and stakeholders generally agreed that better interregional cooperation is essential to addressing seams issues but opinions varied about what to expect from that cooperation — and what outcomes are actually desirable.
NRG Energy’s Tia Elliot pointed out that MISO struggles with project cost allocation even among its own stakeholders. “I think it could be difficult when it comes to interregional planning,” she said.
Calpine Vice President of Market Design Brett Kruse advocated “reasonable expectations with the guy on the other side of the seam,” noting that RTOs will not have identical cost allocations and flowgates. “The other RTOs have already considered [other market operations], determined it’s not for them and moved on,” he said. “It’s best to leave that stuff alone and work on the common areas.”
FERC Action Needed?
MISO Chair Judy Walsh asked, “We know the problem … but are [RTOs] going to be able to work this out, or is it going to take FERC stepping in and ordering this for the common good? Are we kidding ourselves that we will be able to work this out?”
“Your question, I think, is right on target,” Plante replied. “Now we’re dealing with topics and issues that are heavily ingrained in each RTO’s process.” He said mutual respect for different market implementations will be instrumental in “bridging the gap.”
Director Phyllis Currie said RTOs must seek compromise. “What I’m hearing here is not that different from what I’ve heard in California … and I’ve seen it over the years across different industries,” she said. “If everybody keeps coming at the problem the same way they’ve come at the problem time and time again, you don’t get anywhere.”
Megan Wisersky of Madison Gas and Electric said RTOs should not be required to have uniform rules. “I say, vive la différence!”
“My takeaway is we may not ever get to the idea of a seamless seam, but that shouldn’t dissuade us,” said board member Thomas Rainwater.
Plante agreed. “A seamless seam is an oxymoron,” he said.
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