MISO makes suggestions in gas-electric coordination docket at FERC

The Midcontinent ISO told the Federal Energy Regulatory Commission on Nov. 26 that with gas-fired plants becoming a bigger part of its capacity mix, the commission is on the right track in pursuing better gas-electric market coordination.

MISO was commenting under FERC’s Notice of Proposed Rulemaking (NOPR) regarding Coordination of the Scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities, which was issued on March 20. MISO submitted these comments as supplemental to the comments submitted in this docket by the ISO/RTO Council (IRC), to which MISO is a signatory.

“MISO shares the Commission’s concern on the operational and financial challenges faced by natural gas-fired generators in procuring fuel,” it wrote. “With the integration of MISO’s new south region on December 19, 2013, MISO’s portfolio of natural gas-fired generating capacity has grown to 69 GW, an increase from 28 percent to 38 percent. MISO projects natural gas-fired generation will continue growing as a percentage of the total capacity in the MISO region.

“In order to proactively address issues and interoperability challenges between gas-fired generation,Energy and Operating Reserves Markets and the Natural Gas procurement and scheduling, MISO has engaged its stakeholders as well as the Natural Gas industry through its Electric and Natural Gas Coordination Task Force (‘ENGCTF’). MISO held discussions at ENGCTF meetings on this NOPR over the last several months. Feedback was solicited on the impacts of these scheduling reforms, including modifications to MISO’s Day-Ahead Energy and Operating Reserves Market (‘Day Ahead Market’) and Reliability Assessment Commitment processes (‘Forward Energy Markets’).

“Following the North American Energy Standards Board (‘NAESB’) discussions on the Commission’s proposals, MISO developed and discussed a straw proposal for aligning its Forward Energy Markets with the proposed reforms and standards. In general, stakeholders supported MISO’s efforts to address the issues raised in the Commission’s scheduling reforms. However, concerns were raised with moving the close of the Day Ahead Market bidding window to earlier in the day.

“MISO shares these concerns of an earlier Day Ahead Market close, to the extent that the final rule maintains start of the natural gas operating day (‘Gas Day’) at 9:00 a.m. Central Clock Time (CCT), as the benefits the Commission seeks to attain may be limited.

“Specifically, the time period covered by the Day Ahead Market would continue to be split across two Gas Days, while more financial risk would be introduced due to uncertainty around weather and load forecasting, wind forecasting, and resource availability. To the extent that these financial risks affect resource owners’ offers, via a risk premium, commitment and scheduling of generation resources may be displaced by virtual, or financial, offers in the Day Ahead Market clearing, resulting in less nomination and scheduling of natural gas in the Timely Nomination cycle.

“For these reasons, MISO supports the comments of the IRC in this docket, and requests that the Commission consider these comments in the development of the final rule.”

Specifically, MISO said that the commission’s final rule should:

  • Modify the start of the Gas Day to 4:00 a.m. CCT or earlier;
  • Modify the close of the Timely Nomination Cycle to 1:00 p.m. CCT or later;
  • Increase the number of intraday nomination cycles available in accordance with the IRC’s comments; and
  • Continue to evaluate and support efforts to further enhance the flexibility and coordination needed to ensure electric system reliability.
About Barry Cassell 20414 Articles
Barry Cassell is Chief Analyst for GenerationHub covering coal and emission controls issues, projects and policy. He has covered the coal and power generation industry for more than 24 years, beginning in November 2011 at GenerationHub and prior to that as editor of SNL Energy’s Coal Report. He was formerly with Coal Outlook for 15 years as the publication’s editor and contributing writer, and prior to that he was editor of Coal & Synfuels Technology and associate editor of The Energy Report. He has a bachelor’s degree from Central Michigan University.