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S&P Global: Storage Advocates Urge FERC to Reject MISO's Order 841 Compliance Extension Request

Posted by Jasmin Melvin on Mar 22, 2021

S&P Global examined MISO’s request for delay of FERC Order 841 implementation, highlighting AEE and other trade groups’ disapproval of the request. Read excerpts below and the full story here.

Midcontinent Independent System Operator's request to delay by nearly three years its plans for eliminating barriers to electric storage resources' participation in its wholesale power markets drew pushback from clean energy advocates and utilities in the region pursuing development of storage projects…

Order 841 (AD16-20, RM16-23) directed each regional transmission organization and independent system operator to create market participation rules that recognize the unique physical and operational characteristics of electric storage resources…

The grid operator on March 4 asked FERC to further extend to March 1, 2025, the effective date for its tariff provisions to comply with Order 841. MISO argued that the deferment would allow it to accelerate completion of the market system enhancement (MSE) software platform that is set to replace the existing platform in 2025 to better address reliability challenges arising from the fast growth of renewable resources…

Several trade groups countered that "MISO's request ignores the detrimental impact that a further delay in the implementation of the tariff provisions will have on ESRs that had reasonably planned for interconnection and operation based upon the existing MISO-requested, commission-approved operational date of June 6, 2022."

The US Energy Storage Association, American Clean Power Association, Clean Grid Alliance, Solar Energy Industries Association, Advanced Energy Economy and Southern Renewable Energy Association, collectively referring to themselves as the Clean Energy Coalition, added that MISO's request failed to satisfy the commission's criteria for granting a waiver of tariff provisions. That review by FERC considers whether the applicant acted in good faith and whether the request is limited in scope, remedies a concrete problem and lacks undesirable consequences for third parties.

"First, MISO cannot satisfy the commission's good faith requirement due to its failure to keep stakeholders fully informed," the coalition said, pointing to a November 2020 filing from MISO affirming that implementation of the MSE and Order 841 were on track. That annual informational filing on progress toward implementing Order 841 was directed by FERC when it granted the implementation extension in 2019.

"Second, the waiver is of significant scope, as it impacts the capacity, energy and ancillary services markets, and all ESR participants prepared to operate in those markets," the Clean Energy Coalition said. "Third, upgrading the [MSE] software before implementing the Order 841 [market rules] might be administratively beneficial (at least in MISO's view), but is hardly a resolution to a 'concrete problem.' Fourth, the waiver would have undesirable consequences, such as harming third parties that include the Clean Energy Coalition's members."…

Read the full S&P Global story here.

Topics: AEE In The News