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Recently, because of Hurricane Laura (8/27/2020), MISO experienced its largest uplift ever (Revenue Neutrality Uplift during the emergency period, ~$85.3M), which was allocated to the footprint on a load ratio share basis. MISO already has a very complex set of Real-Time Revenue Sufficiency Guarantee cost allocation rules. First, costs are allocated to the causers. Second, only what can’t be allocated on specific causal basis is uplifted to the footprint on a load ratio share basis. Settlements during Hurricane Laura appear to have identified a gap in MISO’s ability to identify cost causers. Specifically, $80M of the uplift was due to costs within the area islanded by Hurricane Laura. In this case islanding provides for further identification of cost causers, yet, that $80M was uplifted to the footprint on a load ratio share basis.
Review and modify as necessary the Real-Time Revenue Sufficiency Guarantee cost allocation rules to ensure that such costs during a capacity emergency are allocated first to cost causers when they can be identified. So that only those costs that can’t be allocated on a specific causal basis are uplifted to the footprint on a load ratio share basis.