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FERC Rejects Retail Suppliers' Concerns Over MISO Capacity Market

November 23, 2015

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Copyright 2010-15 EnergyChoiceMatters.com
Reporting by Karen Abbott • kabbott@energychoicematters.com

FERC rejected several concerns raised by retail suppliers in accepting a compliance filing concerning the Midcontinent ISO's capacity market

The Retail Energy Supply Association had raised various concerns with load forecasting and the allocation of peak load contributions under MISO's tariff. FERC rebuffed such concerns

As summarized by FERC, RESA asserted that despite clear Commission direction, MISO failed to incorporate its obligations to collect data and to use the peak load contribution methodology. RESA argued that MISO must be ordered to modify its tariff to require MISO to collect sufficient historical data to develop the peak load contribution for each LSE and to require MISO to use the data to use the peak load contribution methodology. RESA also asserted that MISO cannot calculate the default capacity obligations without having the right to collect the data. RESA also requested that MISO be ordered to specify in its tariff its obligation to use the peak load forecast methodology once it has acquired sufficient historical data

As an alternative, RESA argued that the better solution to calculating the coincident peak load for LSEs is to have each LSE perform its own load forecast, including LSEs in retail choice regions. RESA argues that it is not necessary to rely on the electric distribution companies for such forecasts, especially if they do not cooperate well with LSEs in their area

FERC said that its prior order contained no requirement for MISO to obtain historical data, as RESA claimed.

Rather, FERC said that the language cited by RESA means that once MISO has acquired sufficient data provided by electric distribution companies, the peak load contribution method will be used.

"Nor ... did the Commission require MISO to use the peak load contribution methodology for all LSEs. That methodology is to be used only if and when the necessary data is available," FERC said.

FERC also said that, "We see no need to specify in the Tariff that MISO is obligated to use the peak load contribution methodology once it has acquired sufficient historical data. The Commission made this determination clear in the June 11 Order, and no further specification in the Tariff is required."

FERC did clarify that MISO’s data gathering obligation includes a commitment to provide LSEs with actual historical peak information it has in its possession for LSEs that are not in retail choice areas and therefore does not pertain to peak load contribution data in retail choice areas.

"With respect to RESA’s claim that MISO’s load forecasting methodology is unduly discriminatory for LSEs in retail choice regions that are not Electric Distribution Companies, and its recommendation that LSEs should submit their own forecasts in retail choice regions, the Commission already accepted the role of Electric Distribution Companies in providing forecasts in these regions in the June 11 Order ... we will not revisit [that issue] here," FERC said

"We are also not adopting RESA’s proposal for LSEs to calculate their own peak load," FERC said

Docket ER11-4081-002

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