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Commissioner Tony Clark Statement
March 14, 2014
Docket No. ER14-990-000

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MISO Tariff Revisions

“I write separately today to address the Midcontinent Independent System Operator, Inc.’s departure from a practical administration of the resource adequacy construct. While I agree with MISO’s mission to properly account for load switching in the region, I disagree on principle with MISO’s proposed solution.

“Under MISO’s current market rules, a Load Serving Entity (LSE) can use Demand Resources (DR) and Energy Efficiency Resources (EE) to reduce its forecasted peak demand and planning reserve margin requirements for a future planning year. The ability of an LSE to net DR and EE from forecasted demand accurately reflects the nature of the demand-side services. By definition, DR and EE reduce the amount of energy usage on the system; they do not supply additional electrons for the grid and do not have performance obligations that are comparable to traditional supply resources. To pretend otherwise by forcing DR and EE to be treated as supply resources, as proposed by MISO, ignores supply-demand dynamics and system operations in the planning year.

“While MISO is correct in pursuing a transparent accounting mechanism for these resources and further clarifying performance obligations, MISO’s proposal to force LSE’s to convert DR and EE into a supply-side resource is a prima facie deviation from reality. I would have preferred alternative options for addressing MISO’s concerns, such as enhanced registration requirements that would have enabled a greater association between DR/EE and the load to which it belongs.

“For these reasons, I respectfully dissent from this order.”