Commissioner Mark C. Christie Statement
May 17, 2021
Docket No. ER19-465
Today’s order denies MISO’s request for an extension of time to comply with the requirements of Order No. 841.[1] I would have granted the request.
MISO requests the extension so that it can replace its existing market system platform with a new Market System Enhancement (MSE) platform. MISO explains that this new MSE platform is needed both to adapt reliably to the evolving resource mix, and to do so in a manner that is cost-effective for consumers. Among other things, MISO notes that it already has significant amounts of wind and solar resources – for which the new MSE is needed to ensure continued reliability – with more on the way.
MISO recognizes that it cannot prioritize both MSE implementation and compliance with Order No. 841 at the same time. Some sort of trade-off is inevitable. Balancing the competing concerns implicated by each, MISO has determined that replacing its existing market system platform should take precedence at this time over implementing new tariff provisions for Energy Storage Resources (ESRs). In this balancing of priorities and challenges, I am disposed to trust MISO’s sound judgment.
MISO has based its request on the need to reduce risks to reliability and avoid unnecessarily higher costs to consumers. If these reliability risks and costs can be reduced or avoided, I believe that they should be.
For these reasons, I respectfully dissent.
[1] Electric Storage Participation in Markets Operated by Regional Transmission Organizations and Independent System Operators, Order No. 841, 162 FERC ¶ 61,127 (2018), order on reh’g, Order No. 841-A, 167 FERC ¶ 61,154 (2019), aff’d sub nom. Nat’l Ass’n of Regulatory Util. Comm’rs v. FERC, 964 F.3d 1177 (D.C. Cir. 2020).