MISO is drafting Tariff language to address under what conditions it can reopen or extend its day-ahead market when necessary to address technical problems.
The RTO occasionally delays the close of the market, but rules for doing so are implied and have never been spelled out in the Tariff.
MISO is looking to clarify Tariff section 39.1.1, which governs the day-ahead energy and operating reserve market trading deadline. The RTO said it’s in need of language that “clearly establishes MISO’s ability to reopen/extend the market [or] the conditions under which MISO would do so.”
“Currently the Tariff language doesn’t really address this,” MISO’s David Savageau told the Market Subcommittee last week.
MISO staff is proposing that it be allowed to reopen or extend the close of the market when “unanticipated events” occur. In a draft, MISO said the conditions would have to be such that they interfere with a transmission provider’s ability to receive or process bids, offers or interchange schedule data. The RTO said it would also consider delaying close of market when a transmission provider’s bid, offer or interchange schedule data is “plainly inaccurate” and likely to hinder their ability to deliver using the market.
MISO also inserted a provision allowing it to extend market hours when missed or incorrect bids, offers and interchange schedule data “are otherwise likely to have a widespread negative impact on the results of the day-ahead energy and operating reserve market, in a manner that adversely threatens or affects the reliability of market operations or of the transmission system.”
MISO said it would post a notice any time it extends the trading deadline. No expected date has been set for MISO to adopt the proposed Tariff additions.
Soon-to-be Eliminated Demand Response Working Group Works on New LMR Deployment Rules
The Demand Response Working Group has completed a review of remaining open issues ahead of its disbanding as part of the stakeholder redesign, said group chair DeWayne Todd. One of those open issues is a change to how load-modifying resources (LMR) will be deployed this summer.
Under emergency pricing beginning in July, market participants with multiple LMR assets will have to identify which asset will be deployed at least 10 minutes prior to an LMR event. Asset owners formerly were required to identify the asset within 24 hours after the event.
Michael Robinson, MISO’s principal adviser of market design, said the RTO is having its legal team look into whether the new rules would necessitate Tariff changes. “We just started the process of having legal look into it. Because the LMR language was written so long ago, there’s nothing in the Tariff to address deployment,” he said.
Last August, FERC accepted MISO’s Tariff revisions to institute emergency pricing (ER15-1776). A vendor working with MISO found that calculating emergency pricing requires information on LMR deployment at the resource pricing node and wouldn’t work with MISO’s current treatment of LMR resources.
MISO Works ‘Triple E Flags’ into Real-Time Offer Enhancements Project
MISO will be including excessive energy exemption (EEE) requests into its real-time offer enhancements project.
The EEE process replaced the uninstructed deviation calculations and penalties. MISO dispatchers can waive excessive or deficient energy deployment charges by setting the EEE “flag.”
“This is under construction, but the project is still scheduled to be implemented in July,” said MISO Senior Real Time Operations Engineer Steve Swan during a presentation. He said that MISO is primarily adding the exemptions so offer overrides get into the five-minute dispatch sooner and automatically, although the option for manual entry would still exist.
MISO plans to test the software in March through June and take the project live sometime in July. Meanwhile, real-time offer enhancements will be the subject of a technical workshop on Feb. 25.
MISO-PJM Interface Pricing Project Heads to Final Four
MISO has until March 1 to decide which option it wants to take concerning pricing enhancements and interchange modeling with PJM.
Dhiman Chatterjee, MISO’s senior manager of market analysis, outlined the next steps for MISO and PJM’s interface pricing project, which is intended to settle longstanding differences in the way the two RTOs price transactions at interface buses. The goal is to end the double-counting that leads to overcharging during congestion contributions and overcompensating when a constraint is relieved.
Chatterjee said four options exist:
- The MISO Monitor’s original proposal that favors a centroid-to-centroid approach where the non-monitoring RTO excludes a transaction’s impact on the constraint;
- PJM’s original proposal that makes use of a 10-bus common interface;
- A MISO and PJM collaborative approach in which financial transmission rights and day-ahead limits are modified if needed to reflect a transaction’s impact; and
- A MISO incremental proposal suggested by MISO’s Monitor in which the centroid-to-centroid method is used alongside MISO excluding a transaction’s impact on PJM constraints while PJM preserves its common interface definition.
“We have all these options on the table, so we need something to compare them against. We did work a lot on developing a baseline,” Chatterjee said.
Chatterjee said if the RTOs decide to go with the collaborative approach, no Tariff changes would be needed, but MISO’s commercial model would be adjusted. MISO Monitor David Patton said he preferred the incremental approach over the collaborative approach because it could solve the issue completely.
Although MISO has until March 1 to make a decision, the RTO said it would have the analysis finalized and be ready to provide a recommended option before a Feb. 18 joint and common market meeting of PJM and MISO stakeholders. MISO said it would follow that up with discussion on the topic at March meetings of the Seams Management Working Group and the Financial Transmission Rights Working Group.
MISO Seeks Leaders for New Resource Adequacy Subcommittee
MISO continues its march toward a revamped stakeholder process. A system-wide note went out requesting leaders for MISO’s newly created Resource Adequacy Subcommittee. Stakeholders and MSC leadership said the portion of the MSC’s charter dealing with capacity needs to be revised so it doesn’t intersect with the RASC’s charter, a point that was raised at January’s Steering Committee meeting.
“There was a pretty robust discussion at the Steering Committee. I imagine that will continue throughout the new stakeholder process,” said Kent Feliks, chair of the MSC.
Feliks said there has also been discussion among the MSC on whether the Steering Committee should absorb the responsibilities of the Data Transparency Working Group and the Stakeholder Governance Working Group.
He also said the topics dissected in the Data Transparency Working Group could be a little dense for the Steering Committee to come in cold. “We don’t want to lose the work that we’ve done in that group, but there’s concern that the Steering Committee isn’t the appropriate place to hold those discussions,” Feliks said.
Jeff Bladen, MISO’s executive director of market design, said the RTO is still working on common issues that may be recurrent in separate meetings. He said the informational forum may be a good outlet for topics that can be examined in multiple groups and committees. “There’s also been the discussion that the Steering Committee will help guide issues to the appropriate venue,” he said.
Meanwhile, Bladen is calling for stakeholders to offer their input on next steps on energy storage issues.
Bladen also said MISO may have to accelerate its timeline for addressing energy offer caps in light of FERC’s Jan. 21 order proposing a $1,000 “soft” offer cap for all RTOs’ day-ahead and real-time markets. (See FERC Proposes Uniform Offer Cap Across RTOs.)
Comments on the Notice of Proposed Rulemaking are due 60 days after its publication in the Federal Register. MISO was expecting to begin conversation on energy offer caps in May.
— Amanda Durish Cook