March 19, 2021

ESA Protests MISO’s Three-Year Delay Request for Order 841 Implementation

ESA jointly submitted comments today with the American Clean Power Association, Clean Grid Alliance, Advanced Energy Economy, the Southern Renewable Energy Association, and the Solar Energy Industry Association (jointly, the “Clean Energy Coalition) to protest MISO’s March 4th request for a three-year extension on its previously-approved June 2022 deadline for implementing FERC Order 841.

MISO’s stated reason for making the delay request is to prioritize and complete implementation of a new software upgrade prior to implementation of its Order 841 compliance. However, MISO failed to inform stakeholders, many of which will be significantly impacted by this delay, that it would seek to dramatically extend the compliance date for Order 841. MISO’s request ignores the detrimental impact that a further delay in the implementation of the Tariff provisions will have on thousands of megawatts of energy storage resources that had planned for interconnection and operation based upon the existing 2022 operational date.

In our comments, the Clean Energy Coalition argues that MISO has failed to meet the burden for a waiver of its tariff provisions with regard to all four criteria that FERC uses to evaluate a waiver request to the previously-imposed deadline. Specifically, we demonstrate that a waiver would disregard stakeholders; would have adverse impacts on energy and ancillary services markets, and all storage participants prepared to operate in those markets; is not a resolution to a concrete problem; and would have undesirable consequences, such as harming third parties that include the Clean Energy Coalition’s members. As a result of MISO’s failure to meet its burden, the Clean Energy Coalition urges FERC to deny MISO’s request.


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