On March four, MISO filed a request to increase the deadline to implement a market participation mannequin for electrical storage assets at FERC. This new request strikes the implementation date from June 2022 to March 2025.

FERC ought to reject this request as a result of the advantages of maintaining wholesale charges simply and affordable with storage participation outweigh the prices of MISO parallel processing present and future market platforms. Electric storage can take part within the power market and capability market and supply ancillary providers. That is the intent behind FERC Order 841, the discover for which was launched in November 2016. Eight years is a very long time to attend for any market participant.


The foremost purpose MISO gave the fee for requesting the extension is relating to scheduling constraints with their market improve mission. MISO has been working at the least since 2017 when MISO modified the mission identify from “analysis” to “enhancement” and referred to as it the “Market Systems Enhancement” program.

After March four submitting, many stakeholder organizations filed a protest at FERC. What is shocking to MISO stakeholders is MISO didn’t current at any stakeholder committee earlier than asking FERC for this extension. Moreover, when FERC Order 841 got here out in Spring 2018 and MISO filed the compliance plan by Dec 2018, stakeholders anticipated MISO to satisfy its promise of going dwell with the 2022 date.

FERC may settle for due to the problem at hand – Market Systems Enhancement (MSE) Project

MISO markets went dwell in 2005. Since then, ancillary providers began in 2007, with MISO turning into a single balancing authority. After a decade of MISO market operations and integrating a number of main utilities within the south, MISO began down the trail of scoping out a brand new market platform. This new market system would additionally handle the technological capabilities of rising applied sciences like storage.

So, FERC may settle for MISO’s reasoning on transferring forward with MSE maintaining the general advantages of MISO market individuals in thoughts.

But 4 extra years is just too lengthy to attend for storage to take part in MISO markets

MISO insists that storage can now take part in its markets beneath a market product referred to as Stored Energy Resource (SER) kind II. SER kind I applies to Beacon Power, like flywheels, which might take part in a single explicit ancillary service referred to as regulating reserve.

But the issue with SER kind II and ESR, the market participation mannequin for complying with FERC Order 841, is that the latter supplies electrical storage assets with technical capabilities to take part in all the MISO markets. Storage will not be restricted to at least one service within the ancillary providers market.

Waiting an extra three years (from 2022-2025) for the storage market to open up when MISO filed and obtained approval from FERC on Storage As a Transmission Only Asset (SATOA) is difficult for non-transmission house owners to swallow.

Meanwhile, hybrid interconnections and stand-alone storage is economical

While the good thing about a brand new market platform is likely to be FERC’s purpose to just accept MISO’s extension request, FERC is aware of and should reconcile storage interconnection requests at MISO and different RTOs. Most of the storage interconnection requests at RTOs, together with at MISO, are “hybrid” in nature – the identical level of interconnection as photo voltaic or different renewable power. FERC has a knowledge request out for RTOs on hybrid interconnections, and the RTO responses are due July 2021.

In addition to hybrid assets, storage is economical on a stand-alone foundation within the California marketplace for capability functions and the New England ahead capability market. MISO has an upcoming 2021/22 planning useful resource public sale. Capacity costs are introduced on April 15. Storage can and may be capable of take part within the capability markets, and that could be a good purpose for FERC to reject MISO’s extension request.


Whenever an RTO asks for an extension request for compliance or an implementation plan, stakeholders’ basic feeling is disbelief. Because RTOs have ample time earlier than a FERC Order because of the Notice of Proposed…

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