Pseudo-Tie Congestion Overlap

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Pseudo-Tie Congestion Overlap Tim Horger Director, Energy Market Operations Markets & Reliability Committee March 22, 2018

Congestion Overlap Background Pseudo-Tie Market-to-Market congestion overlap between two RTOs is a complex issue and has led to FERC Complaints RTO Joint Operating Agreements (JOAs) and included Market-to-Market coordination and settlement rules may not appropriately accommodate the unique modeling, implementation and settlement circumstances associated with Pseudo-Tie Assets (Load or Generation) MISO and are working to better administer Pseudo-Ties as well as mitigate modeling and market impacts that have been identified 2

What is Pseudo-Tie Congestion Overlap? MISO Market MISO collects Real-time Explicit Congestion (M2M and Internal MISO constraints) MISO collects excess congestion via M2M payment from ( receives no FFE) Internal MISO Constraint Pseudo-Tie Generator MISO Internal Constraint Load Market M2M constraint collects Day-ahead congestion on entire path (M2M and Internal constraints) Unhedged congestion for partial path from unit to interface MISO Congestion overlap (M2M only) 3

Solution to Congestion Overlap MISO Market MISO collects RT Explicit Congestion (M2M and Internal MISO constraints) MISO excess congestion removed from M2M payment ( M2M flow reduced) (Phase 1) MISO allows pseudo-virtual in DA to align with RT (Phase 2) Internal MISO Constraint Pseudo-Tie Generator MISO Internal Constraint Load Market M2M constraint DA M2M congestion removed for path from unit to interface (Internal congestion remains) (Phase 1) provides FTR eligibility for entire path (Phase 2) credits/charges will be issued based on DA vs. RT deviations MISO Congestion overlap removed 4

Congestion Overlap Solution: Phase 1: JOA only changes Phase 1 JOA language filed in December 2017 and tentative effective date is on March 1, 2018 The RTOs will coordinate and model firm flows impacts before the Day-ahead run so that the congestion and the Day-ahead LMPs for the Pseudo-Tie Resources will better reflect expected Real-Time congestion. This removes the majority of overlapping congestion. In RT, Market-to-Market settlements will be adjusted to account for Pseudo-tie impacts. This will ensure the Attaining BA receives credit for Pseudo-tie resource flow from the unit to the interface. FERC issued deficiency notice on 12/28/17 with response due in 30 days. 5

Congestion Overlap Solution Phase 2: OA and Tariff Phase 2: June 1, 2018 Pseudo-tie Out of Ability to submit Day-ahead pseudo-tie transactions in order to hedge Real-time explicit congestion charges. Pseudo-tie into Pseudo-tie node will be available in ARR/FTR markets for hedging purposes. Pseudo-tie owner will be refunded/charged for deviations between Day-ahead and Realtime. 6

Definitions Article II of OA OA & Tariff Updates New Day-ahead Transaction for Pseudo-Ties shall mean a transaction scheduled in the Day-ahead Energy Market to the -MISO interface from a generation resource within the balancing authority area that Pseudo-Ties into the MISO balancing authority area M2M Flowgate shall have the meaning provided in the Joint Operating Agreement between the Midcontinent Independent Transmission System Operator, Inc. and Interconnection, L.L.C Updated Balancing Congestion Charges Day-ahead Energy Market Injection Congestion Credit Day-ahead Energy Market Withdrawal Congestion Charges 7

OA & Tariff Updates Definitions Section 1 of OATT New Day-ahead Transaction for Pseudo-Ties shall have the meaning provided in the Operating Agreement. M2M Flowgate shall have the meaning provided in the Joint Operating Agreement between the Midcontinent Independent Transmission System Operator, Inc. and Interconnection, L.L.C. Updated Balancing Congestion Charges Day-ahead Energy Market Injection Congestion Credits Day-ahead Energy Market Withdrawal Congestion Charges 8

OA & Tariff Updates Real-Time Explicit Congestion Hedging Mechanism (Native BA) Schedule 1 Section 1.10.1A of OA & Attachment K in Tariff Rules surrounding how a market participant can submit a day-ahead transaction in to hedge Real-Time congestion for pseudo-ties out of Schedule 9-3 in Tariff Updated item d) to incorporate the Day-ahead Pseudo-Tie Transaction Mechanism to charge or credit RT deviations Schedule 1 Section 3.8 of OA & Attachment K in Tariff Real-Time Market credits/charges will be issued to Pseudo-Tie Transactions based on deviations from Day-ahead schedule transactions. 9

OA & Tariff Updates: Next Steps First read: January MIC and MRC Endorsement: February MIC and MRC, March MC Implementation timeline: (Tentative pending FERC approval) Phase 1: March 1, 2018 Phase 2: June 1, 2018 Detailed spreadsheet example provided with August 2017 JCM materials Allows for user Plug and Play to measure impacts of solution (Phase 1 and Phase 2) http:///-/media/committees-groups/stakeholder-meetings/pjm-miso-joint-common/20170822/20170822- dcpt-phase-2-example.ashx 10