WPPI offers the following feedback re the proposals MISO discussed at the DERTF on 2/12/2014 re dispute resolution (Item 04b Dispute Resolution, 2/12/2024):
- (1.) Proposal, new (s. 4) - Revised 12.g: Any dispute related to registration, review or participation of a DERA that is not within the authority of the Transmission Provider.
- WPPI has no concerns with this revised 12.g (Module A).
- (2.) Proposal, new (s. 5): Disputes related to MISO Reliability Review results will follow the Generator Interconnection Procedure (GIP) process for DER Affected System Studies as developed through the Interconnection Process Working Group, as directed by BPM 015 Section 9. This dispute process is found in MISO's GIP, Attachment X, Section 13.5.
- WPPI thinks it makes sense that disputes related to MISO Reliability Review results will use the dispute process in MISO’s Generator Interconnection Procedures, Attachment X, Section 13.5 Disputes.
- MISO noted that it is evaluating the additional Tariff language necessary to direct such disputes to this process. WPPI thinks such additional Tariff language is necessary (without it, it’s not clear to WPPI how disputes related to MISO Reliability Review results will be subject to Attachment X, Section 13.5).
- (3.) Proposal, 1/11/2024 (s. 7 and 8) – Revision (underlined text) to Module C, Section 38.7D: The Transmission Provider shall review the participation of a DERA in the Energy and Operating Reserve Markets when the DERA’s settlements are successfully disputed more than ten percent (10%) of the time by a relevant LSE and the financial impact(s) of such successful disputes exceed seven thousand five hundred dollars ($7,500.00) for an individual dispute or one hundred thousand dollars ($100,000.00) in the aggregate for all successful disputes.
- WPPI provided feedback on this proposed revision in response to the DERTF feedback request (Compliance Tariff Redlines on Dispute Resolution (MSC-2019-2)) due 1/29/2024.
- MISO’s response (in the Stakeholder Feedback Tool) to WPPI’s feedback, posted 2/14/2024: MISO is evaluating changes to 38.7.D regarding the relevant period and path for DERA settlement disputes as suggested by this comment.
- As a result, before providing further feedback, WPPI is awaiting any MISO revisions to their 1/11/2024 proposal above.