RSC: Operating Guide Information Classification RSC-2021-1 (20210225)

WPPI offers the following feedback on Operating Guide Information Classification:

1. Does your company (Market Participant) want access to Operating Guides for marketing function employees and if so, please explain the perceived benefits?

• Yes. Operating guides affect both market operations and transmission planning. Access to information on operating guides would better allow MPs to understand certain constraints that affect prices. This information would also allow MPs to more meaningfully assess transmission-planning analyses that impact users of the transmission system in daily operations and Transmission Customers who pay for construction, maintenance and expansion of the transmission system.

2. What concerns/suggestions do you have, including classification of information and/or work effort?

• To the extent it takes some effort to reclassify existing Op Guides that effort can be planned for and perhaps spread out over a reasonable period of time.
• That said, it is unclear to WPPI that this reclassification effort will necessarily be time consuming. We agree it will take some time to exclude from the public version of an Op Guide any market sensitive information that is specific to an MP and, therefore, should not be available to other MPs. On the other hand, if the market sensitive information is “market sensitive” only because it is not currently publicly available, it seems reclassification would be unnecessary as any MP (presumably with access to CEII) will have access to the Op Guide. To what extent is the market sensitive information in the existing Op Guides specific to an MP vs. only market sensitive because it is not currently publicly available?

International Transmission Company d/b/a ITCTransmission, Michigan Electric Transmission Company, LLC, and ITC Midwest LLC (collectively, “ITC Companies”) are independent, stand-alone transmission companies that are MISO Transmission Owners.  The ITC Companies appreciate MISO’s outreach on this issue, and appreciate the opportunity to comment, solely in their capacity as MISO Transmission Owners.  In response to the first question, the ITC Companies believe that MISO has not adequately explained the extent to which allowing additional access by SMEs to Operating Guides would provide any defined, measurable benefit; much less benefit that would outweigh the increased risk and administrative burden of allowing MFEs to access Operating Guides.  Specifically, it is the ITC Companies' understanding that, in order to implement the requested deviation from the current status quo, MISO would also be required to implement new access processes/procedures (including revising standard agreements), make changes to the MISO Extranet, and/or that MISO would also be required to perform a joint review, with relevant TOs, of all 200+ existing Op Guides.  It is also the ITC Companies' understanding that any change to the existing status quo regarding SME access to Operating Guides would require a revision of the MISO Transmission Owners Agreement, which ITC views as a significant legal and administrative hurdle that has not been justified.  In summary, while MISO has demonstrated that significant risks and administrative burdens would result in any deviation from current practice regarding SME access to Operating Guides, MISO has not made a satisfactory business case that would justify any such deviation from the current status quo.  The ITC Companies thus respectfully oppose any change to existing MISO practice regarding SME access to Operating Guides at this time.

Ames, MGE, MJMEUC, and MRES generally support WPPI Energy's feedback.

Please let me know if you'd like to discuss.

David Sapper

dsapper@ces-ltd.com

American Transmission Company (ATC) is not a market participant and, as such, has no feedback on question #1.

Regarding concerns or suggestions in line with question #2, we have the following comments:

ATC collaborates with MISO on Operating Guides and these documents contain market sensitive information. Currently, all documents are treated as non-public transmission function information (NPTFI).

1. By creating different categories of Operating Guides, we introduce the risk of incorrectly classifying documents, primarily labeling a document as public transmission function information when it should have been coded as NPTFI. Since that document would not be publicly available (e.g., behind the MISO Extranet due to CEII concerns), an entity that shared the document with its affiliated Market Function Employees may inadvertently violate the FERC Standards of Conduct.

2. We foresee a possible unintended consequence with two different types of documents. This change may result in phone calls to the real-time operating desk from Market Function Employees. When a system event requiring use of a MISO Operating Guide is occurring, the operating desk is often under stress and time pressure. This is an error prone situation. When using temporary or emergency Operating Guides, the operating desk may be implementing an Operating Guide for the first time, which further increases the likelihood of error. By increasing the potential for an affiliated Market Function Employee to call the operating desk, we foresee the possibility of accidentally communicating NPTFI regarding the system conditions or incorrectly reading and applying an Operating Guide category related to what can or cannot be communicated in that moment.

Given MISO has indicated that changes may be required to the Transmission Owners agreement, the MISO tariff, MISO business practice manuals and/or MISO procedures, we recommend clearing identifying the benefits, costs, and risks to allow MISO and its stakeholders to determine if the requested change is a priority for the MISO community.