MISO is Eliminating the Dual Registration of LMR as EDR
MISO’s third demand response filing in 5-week period increases uncertainty about the future of DR market participation.
On April 25, 2025, MISO filed a proposal with FERC to eliminate the dual registration of Load Modifying Resources (LMRs) as Emergency Demand Response Resources (EDRs), effective with the 2026/27 Planning Year. MISO’s filing responds to concerns that dual-registered resources receive capacity payments with minimal expectation of performance, especially as EDRs are called only after LMRs in emergency operations.
The filing was accelerated by FERC enforcement actions involving Voltus and reflects longstanding recommendations from MISO’s Independent Market Monitor. Going forward, market participants must choose between registering as LMRs or EDRs, but not both, to qualify for capacity payments. This change, combined with broader Demand Response and Emergency Resource reforms underway, adds uncertainty for DR providers evaluating their participation in MISO’s markets.
Note - This has been a busy week for electric grid nerds. Spain and Portugal had a blackout. Too soon to tell what caused it. Hope to dig into it at a later date.
Closer to home, MISO had its capacity auction. I wrote about the results here.
Background
On Friday, April 25, 2025, MISO filed a proposal with FERC to eliminate the dual registration of Load Modifying Resources (LMRs) as Emergency Demand Response Resources (EDRs). This FERC filing was expected, as MISO has been discussing this change with stakeholders since early 2025.
MISO explains that EDRs are rarely called upon, as they are dispatched only after LMRs under MISO’s emergency operating procedures. As a result, EDRs have been receiving capacity payments with very little chance of actually performing. To address this issue, MISO is eliminating the option to dual-register a resource as both an LMR and an EDR.
In a separate initiative, MISO’s Demand Response and Emergency Resource (DR & ER) Reforms proposal introduces a new resource category: LMR Type II, which would require a 30-minute notice to curtail during emergencies. Under these reforms, market participants will have several options for registering demand response resources: DRR–Type I, DRR–Type II, LMR–Type I, LMR–Type II, Non-Emergency BTMG, and EDR.
MISO initially proposed eliminating the EDR category altogether, effective in the 2028/29 Planning Year, but stakeholder pushback led MISO to retain the EDR option. Instead, MISO decided to move forward with eliminating only the dual registration of LMRs as EDRs, effective with the 2026/27 Planning Year.
The timing of the April 25 filing was also influenced by FERC Enforcement Action involving Voltus. In its transmittal letter, MISO noted:
"Voltus engaged in practices such as registering demand resources without proper authorization and dual registering its LMRs as EDR resources. Voltus exploited the dual registration mechanism to receive Capacity payments without a genuine commitment to perform during Emergencies."
Concerns about EDRs are not new. In 2024, MISO’s Independent Market Monitor (IMM) recommended eliminating EDRs altogether, noting that:
"EDRs are called very late in emergency procedures and have never been called by MISO. They represent an effective strategy to receive capacity payments with virtually no chance of having to perform."
According to the IMM’s 2024 State of the Market Report, MISO had 552 MW of EDRs cross-registered as LMRs in 2023. Unlike LMRs, EDRs are not subject to a must-offer obligation unless they are cross-registered and cleared in the Planning Resource Auction (PRA). EDRs can also set prices with their offers, and may be dispatched during emergencies when prices rise to as much as $3,500/MWh.
MISO has proposed that the 2025/26 Planning Resource Auction be the last year that dual registration of LMRs as EDRs is permitted. MISO is requesting a July 19, 2025, effective date for this change at FERC.
Implications for DR Providers:
The elimination of dual registration means that capacity payments tied to emergency services will only be available through the EDR registration path. Combined with other changes — such as upcoming baseline measurement reforms and the introduction of LMR Type II — the evolving landscape creates significant uncertainty for DR providers assessing their future participation in MISO’s markets.