Docket Nos. ER22-2363-002, ER22-2363-000
I concur in today’s order granting MISO’s request for an extension to the effective date of its Order No. 881 compliance filing because I believe that MISO has adequately demonstrated that the delays are industry-wide and beyond its control. I write separately, however, to request that MISO work proactively and transparently with stakeholders—including the Organization of MISO States—to implement the ambient adjusted line ratings, including real-time and emergency line ratings, contemplated by Order No. 881 before the deadline extended in today’s order and as soon as the required software becomes available.
Ambient adjusted line ratings enable efficient use of the transmission system by accounting for the true capabilities of the transmission system when weather conditions change. This practice allows the grid operator to move more energy with less infrastructure, which reduces costs and can increase reliability.[1] MISO’s Independent Market Monitor estimates that between 2023 and 2024, transmission customers paid an additional half a billion dollars due to the lack of temperature adjusted ratings and emergency ratings.[2]
The Commission previously accepted MISO’s compliance filing with an effective date of July 11, 2025.[3] Now, two years later, MISO is requesting a to-be determined date no later than December 31, 2028. This three-year long extension is one of the longest granted to date under Order No. 881 for any RTO[4] and comes at a time when demand in the region is expected to grow, margins are expected to tighten, and already high costs are expected to rise.[5] Working with stakeholders, MISO has an opportunity to deliver a huge win for its ratepayers by implementing all—or even some components—of Order No. 881 ahead of schedule.
For these reasons, I respectfully concur.
[1] OMS Answer at p. 2.
[2] Id. at 6.
[3] Midcontinent Indep. Sys. Operator, Inc., 183 FERC ¶ 61,194 (2023).
[4] New York Indep. Sys. Operator Inc., 186 FERC ¶ 61,237 (2024) (granting a three-year extension to implement Order No. 881 tariff revisions until December 31, 2028); ISO New England Inc., 191 FERC ¶ 61,163 (2025) (granting a one-year extension to implement Order No. 881 tariff revisions up to and including December 15, 2026); Southwest Power Pool, Inc., 191 FERC ¶ 61,021 (2025) (granting a one-year extension to implement Order No. 881 tariff revisions until September 1, 2026); Cali. Indep. Sys. Operator Corp., 191 FERC ¶ 61,095 (2025) (granting a one-year extension to implement Order No. 881 tariff revisions until December 17, 2026); PJM Interconnection, L.L.C., 190 FERC ¶ 61,204 (2025) (granting a nine-month extension to implement Order No. 881 tariff revisions up to and including April 15, 2026).
[5] OMS Answer at 6.