MSC: MISO Recommendation on Energy Replacement on Common Bus Issue submitted by Entergy (20230302)

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Energy Markets

In the March 2, 2023 meeting of the Market Subcommittee (MSC), stakeholders were invited to review and submit feedback on the MISO Recommendation on Energy Replacement on Common Bus Issue submitted by Entergy

MISO recommends categorizing this issue as “Inactive” and evaluating it under the broader Multiple Configuration Resource (MCR) initiative, after internal investigation on the issue submission, discussions with the Independent Market Monitor (IMM) and Entergy, and consideration of potential market impacts and the complexity of implementation.

Multiple factors were considered in developing MISO’s recommendation as described below:

  • Potential market impacts: The existing RSG charge generation deviation calculation provisions allow Market Participants to self-supply/replace resources across its portfolio for periods prior to the Notification Deadline (4 hours) with deviations on the failed resource and replacement resource netting against each other.  For periods after the Notification Deadline, MISO may view the common bus replacement resource’s total time-to-start as inadequate and take more expedient action by committing a shorter-lead resource elsewhere in the footprint before the common bus replacement resource can be available. 
  • Complexity of implementation: Updates to market systems, settlement processes, and other supporting tools would be required to incorporate the proposed change. Recognizing the complexity of the settlement rules around the RSG charges, a significant amount of time and effort would be required to explore and develop new logic for both the DART and Settlement systems, and further complications would be introduced by the proposed changes.

Please provide feedback by March 17, 2023.


Submitted Feedback

WPPI can appreciate Entergy’s interest in workarounds (avoid Revenue Sufficiency Guarantee charges if replace lost energy at the same bus) as we await implementation of the Multiple Configuration Resource project (which will be sometime after the completion of the Market System Enhancements project). That said, we support MISO’s proposal to categorize the issue as “Inactive” for the following reasons:

  • Seems this issue has a solution, albeit we need to wait for it, and is in better position than issues for which we don’t a solution today or in the future.
  • As MISO noted, the calculation of RSG charges already allows for some “aggregation” (within an Asset Owner) prior to the 4-hour Notification Deadline that has the potential to mitigate/eliminate RSG changes if lost energy is replaced at the same (or different) bus.
  • We found MISO’s characterization that implementing Entergy’s proposed change would be challenging credible.

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