FERC Filings
EPSA's Motion to Intervene Out of Time and Comment on MISO's Compliance Filing to Add Attachments
COMMENTS
EPSA appreciates the effort that MISO and its stakeholders have devoted to this filing, and the importance of clearly outlining the responsibilities of transmission providers and owners, and generators, to take all reasonable actions to ensure a well-functioning grid. Accordingly, EPSA vigorously supports any and all measures deemed necessary to maintain and enhance system reliability, including the avoidance or alleviation of Emergency Conditions. In this regard, the fair and nondiscriminatory sharing of these burdens, and the specific circumstances and procedures for imposing them, are especially important.
Therefore, EPSA urges the Commission to closely scrutinize the tariff provisions relating to the rescheduling of planned outages, particularly requests to “voluntarily” reschedule planned outages before an Emergency Condition actually exists. Due to the potential financial exposure attendant to such decisions, EPSA recommends that the Commission direct MISO to clarify and describe with more specificity the circumstances under which generators may be asked to voluntarily reschedule planned maintenance outages.
In proposed Attachment Y, MISO explains that it “has authority to direct Generators to provide any of the following services during an Emergency Condition…[including] (4) defer[ing] a scheduled outage.” It further states that such requests can be made “either directly or through a Control Area Operator.” Additionally, however, in Attachment Z, MISO seeks authority to request generators to “voluntarily” reschedule outages before an Emergency Condition develops. Particularly:
the Transmission Provider may request that a Generator voluntarily reschedule a previously scheduled maintenance outage in order to prevent or minimize other events that could adversely affect the reliability of the Transmission System, including events that the Transmission Provider believes may give rise to, but have not yet resulted in, an Emergency Condition.
In light of the unprecedented nature of this proposed tariff language, and the overall vagueness of the section describing the circumstances under which MISO may ask a Generator to voluntarily reschedule a planned outage, raises serious concerns. Generators devote substantial time and effort in planning maintenance outages, which are submitted to MISO a minimum of one year in advance. Often, business arrangements and transactions are structured around, and in anticipation of, planned maintenance outages. In light of this, rescheduling outages can be disruptive and costly to a generator. Accordingly, EPSA urges the Commission to direct MISO to clarify the circumstances justifying what it refers to as a “pre-emptive response” to developments signifying “abnormal system conditions arising due to unexpected events.”
It is particularly critical that the Commission require MISO to provide a transparent framework for “voluntary” outage rescheduling because MISO proposes that generators who decline to “voluntarily” reschedule outages face uncertain cost responsibility if an Emergency Condition ensues. Specifically, MISO proposes that generators who refuse to voluntarily reschedule a planned outage “shall be subject to the direct cost assignment provisions set forth in Section C.1 of Attachment Y” if the refusal “results in the anticipated Emergency Condition.” At a minimum, and before subjecting generators to such potentially onerous costs (essentially requiring generators to be virtual insurers of MISO’s actions), EPSA believes that the Commission should direct that Attachment Z require MISO to determine the likelihood of a system emergency with a greater degree of certainty.