The Midcontinent Independent System Operator (MISO) has introduced new requirements that could potentially disqualify Voltus’ 450 MW of demand response resources from its upcoming capacity auction. This situation is highlighted in a complaint filed by Voltus with the Federal Energy Regulatory Commission (FERC).
According to Voltus, MISO’s tariff now mandates that market participants provide results from “real power tests” to register demand resources as load-modifying resources for capacity auctions. This is necessary if they don’t have actual performance results from a MISO event. Additionally, participants must have contractual rights to these demand resources.
Recently, MISO adjusted its testing methodology shortly before the deadline for the 2025/26 planning year tests, which Voltus claims complicates the registration process. A second change to the testing requirements occurred just weeks later, including new contract stipulations specifically aimed at aggregators of retail customers like Voltus, which are distinct from standards faced by utilities.
Voltus expressed that MISO’s abrupt changes to these requirements could have severe consequences for market participants, with a registration deadline for load-modifying resources set for March 1. This tight timeline raises concerns that many contracts between demand response aggregators and their customers won’t align with the new MISO requirements, making it impractical to renegotiate agreements before the auction.
This situation could result in hundreds of megawatts being excluded from the auction, which not only threatens resource adequacy but could also lead to increased clearing prices.
Voltus argues that these changes should have been addressed through its tariff rather than by notice at a stakeholder meeting. The company is urging FERC to mandate that MISO revise its requirements related to demand response by adjusting its tariff.
Voltus has requested a decision on its complaint by February 14. If FERC cannot meet that timeline, they suggest that MISO should retract the new terms while FERC reviews the complaint.
Earlier in December, Voltus had already approached FERC with another complaint asking for permission to replace demand response resources if they become unavailable, such as when a business shuts down.
Voltus stated that ensuring the ability to make such replacements is crucial for maintaining reliability. They noted that when generators go offline, they can be replaced, and there is no justification for treating load-modifying resources differently.
This month, Voltus has also settled a case by agreeing to pay $10.9 million and return $7.1 million in profits due to allegations of misrepresenting demand response resources with MISO, which was approved by FERC.
FERC has handled several enforcement cases linked to demand response in MISO markets, reflecting ongoing scrutiny in the sector.