On November 17, 2025, FERC accepted the Midcontinent Independent System Operator, Inc.’s (MISO) proposed revisions to its Open Access Transmission Tariff (OATT) to modify real power testing requirements for Demand Resources. MISO specifically proposed more stringent requirements for Demand Resources seeking waiver of performing real power tests and real power tests for Demand Resources using a firm service level baseline. FERC accepted the proposed revisions as just and reasonable, finding the proposed revisions standardize testing procedures for Demand Resources.
MISO’s OATT requires Demand Resources to show demand reduction capability for each Planning Year by either conducting a real power test or satisfying MISO’s Scheduling Instructions during the previous Planning Year. MISO’s OATT allows for Market Participants to skip conducting a real power test and instead submit operational data or pursue an alternative mechanism if: 1) there was a regulatory restriction against a Demand Resource conducting a real power test, or 2) a Market Participant sought waiver of conducting a real power test in exchange for a higher penalty for under- or non-performance of a Demand Resource.
MISO’s proposed tariff revisions sought to revise the standards for real power tests and the criteria for seeking waiver of real power testing requirements for the 2026/2027 Planning Year. Under MISO’s proposal, Demand Resources using a firm service level baseline must conduct a real power test and demonstrate the ability to reduce Demand: 1) at least 80% of the maximum hourly Metered Demand at the start of the test and ending the test at or below the firm service level, or 2) at or above the maximum Demand consumed during the planned Resource Adequacy hours at the start of the test and ending at or below the firm service level. For Demand Resources not using a firm service level baseline, the Demand Resource must show 100% of the registered capacity value. MISO also proposed stricter requirements for those seeking waiver of a real power test, requiring Demand Resources to show one of the following: 1) participation in a real demand program where the applicable regulatory authority precludes or waives a real power test, 2) for the 2026/2027 Planning Year only, that the Demand Resource is participating in a retail demand response program overseen by a regulatory authority that meets OATT requirements, or 3) within three years before the start of a Planning Year, the Demand Resource successfully responded to at least one Scheduling Instruction and has not otherwise changed in operation.
MISO also proposed new data submission requirements for those seeking waiver of a real power test, a new LMP proxy price under emergency conditions, and a temporary methodology for calculating Seasonal Accredited Values for Demand Resources during the 2026/2027 and 2027/2028 Planning Years. MISO argued the proposed OATT revisions would standardize testing requirements, prevent fraudulent registrations of Demand Resources, and ensure Demand Resources can deliver their stated capacity.
FERC accepted the proposed OATT revisions as just and reasonable and not unduly discriminatory with an effective date of July 15, 2025. In particular, FERC found that MISO’s proposed revisions standardize existing testing procedures for Demand Resources and will provide greater certainty that Demand Resources will be available when needed by MISO. FERC also found the revisions’ effective date was appropriate to ensure application of the revisions to the maximum number of Demand Resources.
FERC’s order, issued in Docket Nos. ER25-2845-000 and ER25-2845-001, is available here.