Update on Failed Intertie Transaction Guidelines with MISO
March 31, 2005
Guidelines for Determining when Failure for ‘Improper NERC Tagging’ in the Michigan Control Area (MISO) Jurisdiction May Breach IESO Market Rules
At the March 23, 2005 meeting of the IESO’s Intertie Trading Sub-Committee, the issue of how the Market Assessment and Compliance Division (MACD) will treat failures to acquire ramping capacity in the Midwest Independent System Operator (MISO) was discussed. MISO’s procedures for obtaining ramping capacity are one of the elements that market participants must address in order to schedule transactions between MISO and the IESO-administered market. MACD subsequently solicited comments from market participants on its approach to ramping vis-à-vis its enforcement of the market rules.
After considering the matter further, MACD has decided to treat the acquisition of ramp in the same way as it treats non-firm transmission when reviewing whether failed transactions potentially breach the market rules. Therefore, if a transaction with MISO fails because the market participant did not obtain adequate ramping capacity, this will not be considered a bona fide or legitimate reason for failing the transaction and it will be subject to further review. The rationale for this position is that acquiring ramping capacity is a MISO market obligation for successfully navigating its market, and market participants can obtain information to aid in their determination of ramp availability. In addition, MACD will continue to observe a three per cent safe harbour on MISO transactions.
If a failed transaction with MISO leads to an investigation by MACD (Notice of Alleged Breach), the market participant will always have the opportunity to provide reasons why the failure to acquire ramping capacity was not within its control.