Why MISO Ended Mock Testing
The change stems from real-world reliability failures. In prior capacity periods, some demand response resources that passed hypothetical testing scenarios failed to actually deliver their committed megawatt reductions when MISO called real emergency events. This created a phantom capacity problem—the grid operator counted on reductions that never materialized.
Under the new regime, every DR resource participating in the 2026/2027 PRA must demonstrate its load reduction capability through verified, actual performance tests conducted under conditions that mirror real dispatch scenarios.
Commercial Impact
For commercial and industrial facilities using demand response as a revenue stream or cost offset in MISO territory, the compliance bar just rose significantly:
- Equipment readiness: Automated load shedding systems (BMS controls, generator transfer switches, HVAC cycling) must be proven functional under real conditions, not simulated scenarios.
- Aggregator accountability: Curtailment Service Providers (CSPs) managing portfolios of DR assets will face tighter scrutiny. Facilities that cannot demonstrate capacity will be removed from bids.
- Revenue risk: Any facility that fails the real test loses its capacity accreditation for the 2026/2027 planning year (June 2026 - May 2027), forfeiting monthly capacity payments.
Immediate Action Items
- Schedule a real curtailment test with your CSP before the March 26 offer window opens.
- Verify BMS automation can execute load reduction within the required dispatch timeframe.
- Confirm metering and telemetry equipment meets MISO's updated verification standards.
- Document baseline load profiles to establish the pre-curtailment benchmark for your facility.