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EPSA Suggests Improvements to MISO and SPP
" EPSA members that participate in MISO's market and stakeholder process appreciate the progress and the value that MISO's services provide. EPSA is not recommending a complete overhaul of MISO's existing tariff requirements, but rather asking that MISO be directed to re-examine its existing structure and make small changes to comply with the directives and goals of Order 719."
"Competitive suppliers are especially encouraged that SPP is more seriously contemplating a congestion management market. However, there are some discrete incremental changes that the Commission should order..."
WASHINGTON, D.C. - Yesterday, EPSA filed comments with the Federal Energy Regulatory Commission (FERC) suggesting improvements to the MISO and SPP regional markets. EPSA's comments, submitted in response to RTO's Order 719 compliance filings, focus on RTO governance, state access to confidential information and scarcity pricing. Both filings applaud the RTOs and the Commission for continuing to make improvements to organized markets. Order 719 refined elements of the organized wholesale electricity markets and required compliance filings by each RTO.
In both RTOs, EPSA suggests changes to governance structures, specifically the stakeholder process. In MISO, EPSA is concerned that too many tariff-changing decisions are discussed and approved in stakeholder working groups that may not always have the appropriate representative balance. "All proposed tariff changes should go through the Advisory Committee. This would serve to strengthen the structural integrity of the stakeholder process by ensuring that all market participants get a vote on tariff changes at an equally weighted level," EPSA says. In SPP, EPSA is concerned that the stakeholder process does not fully satisfy the inclusiveness requirement due to a "three strikes and you're out" rule.
Both filings also address an individual state's access to confidential information by suggesting tailored requests to the market monitor. Order 719 not only gave market participants the ability to review data for confidentiality concerns, but also the ability to contextualize and supplement that data, EPSA says, but these opportunities are missing from SPP and MISO's filings. EPSA points to ISO New England's information policy as a process to be emulated.
Finally, EPSA asks FERC to find MISO's scarcity pricing discussion incomplete, as there was not a robust stakeholder process around the issue. Because MISO already has a FERC-approved mechanism through its Ancillary Services Market (ASM), MISO did not allow for stakeholder discussion pursuant to Order 719. "As the tariff is written now, the ASM only put scarcity pricing into effect after the imposition of several emergency provisions, which does not adequately provide market signals reflecting scarcity or shortage conditions to properly or fully incent market responses. Such an approach is not sufficient to accurately reflect the value of energy or to incent proper demand participation; therefore, it is still a barrier in providing appropriate price signals and a barrier to demand resources" EPSA says. Order 719 found that "rules that do not allow for prices to rise sufficiently during an operating reserve shortage to allow supply to meet demand may not produce prices that accurately reflect the value of energy, and by failing to do so, may harm reliability, inhibit demand response, deter entry of demand response and generation resources and thwart innovation."
CONTACT: JOHN SHELK
(202) 349-0154or 703-472-8660
EPSA is the national trade association representing competitive power suppliers, including generators and marketers. These suppliers, who account for nearly 40 percent of the installed generating capacity in the United States, provide reliable and competitively priced electricity from environmentally responsible facilities serving global power markets. EPSA seeks to bring the benefits of competition to all power customers.