MTEP21 DRAFT Report Substantive Feedback

WPPI Energy offers the following substantive comments on the  MTEP21 study:

1. As described in Chapter 4, WPPI proposed an alternative to Project 20029.  Our goal was to put forward a revision of the planned reliability project that, in conjunction with other transmission upgrades, could also address a chronic constraint pattern with no currently identified solution.  The analysis validated this expectation, showing that the change would create a stronger 161 kV source.  While the alternative exacerbated some constraints—while relieving others—for the most part the exacerbated constraints would be relieved if the other transmission upgrades necessary to address the current congestion issue were constructed.  WPPI agreed that, for the purposes of the current MTEP analysis, and in the context of the Osceola-area voltage issue that motivated project 20029, it is reasonable to retain the original proposal in the candidate Appendix A list, with the understanding that MISO could evaluating the alternative in the context of the ongoing LRTP study.  We plan to propose the alternative and ancillary projects—which appear to have potential to relieve the existing congestion pattern sooner than existing LRTP proposals—to the LRTP process. 
2. While not described in the draft MTEP Report, part of the MTEP21 study, as in previous years is a transfer analysis.  MISO added an “East of MISO to SPP” transfer scenario this year to attempt to simulate the February 2021 cold-weather event.  We applaud this attempt to account for recent significant events in MISO’s analysis.  However, the results of that simulation failed to identify the limitation that led to a transmission emergency on February 16 and associated shedding of load in southeastern Illinois.  While the precise conditions of that day are unlikely to be repeated, and while it is difficult to anticipate all possible extreme scenarios, we believe the Illinois load-shedding event calls for a MISO effort to identify the system weaknesses that led to the transmission emergency and identification of potential solutions for consideration.  While we would not want to pre-judge any such analysis, it appears to us that better connections between the southern Illinois and southern Indiana EHV systems could be effective in this regard, as could better connections between the MISO and TVA EHV systems in western Kentucky.

ACP Comments Regarding MTEP21 Draft Report

September 1, 2021 

The American Clean Power Association (ACP) is a national trade association representing a broad range of entities – including renewable developers, transmission owners, utilities, manufactures, suppliers, financiers, marketers and customers – with a common interest in encouraging the expansion and facilitation of wind, solar and storage energy resources.  

ACP appreciates this opportunity to briefly comment on MISO’s MTEP21 Draft Report, and applauds MISO’s ongoing work to identify transmission projects in MTEP21 necessary to meet customers’ demand for safe, reliable and low-cost energy.  In particular, ACP notes its strong support for MISO’s Long-Range Transmission Plan process, designed to reliably support the portfolio shift underway across the MISO footprint.

ACP collaborated with the Environmental Sector in crafting its MTEP21 comments, and will simply note here that it supports and endorses those comments.

ENVIRONMENTAL SECTOR COMMENTS TO MISO’S DRAFT MTEP21 REPORT

The Environmental Sector appreciates this opportunity to comment on the draft MTEP21 report and we commend the work of MISO staff and stakeholders to identify and move forward with solutions to the pressing needs of the MISO system in the face of significant change and increasing uncertainty. We encourage MISO to continue emphasizing what is readily apparent from this year’s MTEP report: that this is just an initial step in MISO’s effort to enable the resource transition being driven by state and utility commitment, consumer demand, and economics. These comments reflect the Environmental Sector’s points of priority as MISO works to finalize the MTEP21 report. We look forward to continuing our work with MISO to finalize this MTEP report and continue our efforts to advance the Long-Range Transmission Planning (LRTP) process.  

MTEP21 should continue to emphasize the urgency of MISO’s transmission planning efforts. 

MISO should continue to emphasize the urgency that must be placed on transmission planning efforts, and in particular the LRTP. We are truly in the midst of a transformational change across the MISO system. MISO reporting and analysis has done a good job, from a system perspective, of articulating the rapidly changing landscape, identifying issues, and establishing processes to identify solutions.^[1] But MISO must continue to stress the urgency of moving the deliberative processes towards implementable solutions.  

Adding to the urgency to meet the state and consumer-driven demand for clean energy on the MISO system are the growing impacts of climate change that will stress the MISO system in ways not experienced before. It is worth noting that the draft MTEP21 report makes no mention of climate change even as the identification of increasingly severe impacts and the calls for rapid decarbonization from the global scientific community and the majority of Americans grow urgent.^[2] It is imperative that MISO confront this challenge in a robust manner and include a discussion of this in its final MTEP report.  

Increased frequency and intensity of extreme weather events, like the February arctic event^[3] and Hurricane Ida just in the past 7 months, are being driven by a warming climate and will exacerbate risks to the MISO system. In addition to these isolated but extreme events, a general uptick in warmer and cooler temperatures that drive demand has resulted in an increase in the annual number of Max Gen events documented throughout the system and increases in periods of highly concentrated peak LMP prices across the footprint.^[4]These are just the beginning signs of a system under stress from a changing climate.  

The increased flexibility, transfer capability, and diversity of resources that will be delivered by the LRTP process will be critical tools in MISO’s ability to cost-effectively withstand the impacts of climate change. The performance of the Multi Value Projects have shown comprehensive long-term value in mitigating issues like peak pricing and Max Gen events, while providing important regional and interregional transfer capability that will help avoid outages and enhance stability during extreme weather events.^[5] 

In the final MTEP21 report, we encourage MISO to discuss climate change, its potential impacts on the MISO system, and MISO’s ongoing efforts to confront these challenges, including the potential for LRTP and other initiatives underway at MISO to provide cost-effective solutions.  

LRTP serves as an example to the rest of the nation, but does not obviate the need for additional initiatives.  

As MISO has embraced the evolution underway across its system, it has recognized that we need to think differently and creatively about how transmission fits between generation and load. We applaud MISO for adopting the LRTP process as described in Section 1.2 of the draft MTEP21 Report. It should serve as a model for other RTOs across the nation.  

Planning for more robust and resilient regional transmission will save billions of dollars compared to the alternative of not planning for it but building it when we are forced to. Planning now means lower costs in the future to residents, municipalities, and businesses. Through LRTP, MISO is taking the lead amongst RTO’s and ISO’s in recognizing that the grid is changing, and that it is changing faster than anyone had previously anticipated. “No regrets” requires bold action, and MISO has the opportunity to lead the country in this transformation, but only if it seizes the moment we are in today. Indeed, the LRTP process should have come sooner, and we urge MISO to make the LRTP an iterative process to be conducted at regular intervals as we continue to experience rapid and significant change across the system.  

Similarly, we urge MISO to continue improving its planning processes, including by maintaining its commitment to, and including a discussion in MTEP21 regarding, initiatives already underway so that stakeholders maintain awareness of MISO’s trajectory to building a more inclusive and holistic transmission planning process. For example, we urge MISO to discuss its ongoing investigation and exploration into consolidated planning (IR # 90) that would help to break down the planning silos and improve the flow of information between MISO and its members to better inform the transmission planning process. We also encourage MISO to further discuss its interregional planning processes so that stakeholders and MISO’s Board of Directors are better informed of the challenges inherent in those processes, how MISO is addressing those challenges, and what to expect in the near future from MISO and its neighbors in terms of solutions.  

MTEP should recognize the need for more focus and increased scope of interregional planning efforts beyond the JTIQ

In section 3.3 on Interregional Studies we appreciate the focus MISO and SPP have placed this year on the Joint Targeted Interconnection Queue (JTIQ) study. Engaging in this interregional planning effort to identify transmission solutions that can help facilitate generator interconnection near the seam and bring economic and reliability benefits to load has important potential to help address key challenges faced by both MISO and SPP. One aspect of this effort will require the development of a cost allocation methodology that allows both generators and load to share the burden of the costs for transmission solutions, as both will benefit from any identified upgrades. As is always the case, cost allocation may be the most challenging part of JTIQ, but will be critical to addressing the log jam of generator interconnection projects along the seam that are currently unable to move forward. 

The initial results included in the draft METP21 report show potential solution sets (27, 28, and 29) that address most of the identified constraints in the JTIQ models. Some of these solutions sets also seem to be showing positive economic benefits to load. We urge MISO and SPP to continue to refine the solutions and iterate on the analysis to identify the best solution sets that can mitigate all the constraints and bring high value to both generators and load. It will be critical that MISO and SPP provide a solid estimate of these benefits to justify the approval of any solutions so that load can be assured that benefits meet or exceed costs, and generators can be assured that their total interconnection costs still result in financially viable projects. Further discussion on this effort and what stakeholders should expect going forward should be included in the MTEP21 report.  

Our sector is also disappointed in the lack of any other substantive interregional planning efforts between MISO and its primary neighbors, SPP and PJM. MISO did not engage in Coordinated System Planning on either of these seams in 2021. While it may not be necessary to complete interregional studies every year, two drivers suggest that MISO should be expanding its interregional planning efforts now and into the future. The February extreme cold snap which severely impacted Texas and other southern states, showed the importance of interregional support to maintain system reliability and meet load. 

During this event, generation from PJM was engaged to support load, and energy was flowing from PJM, through MISO to SPP. MISO’s interregional planning efforts in the past have been focused on addressing economic congestion on market-to-market flowgates and reliability needs right near the seams. These studies have not contemplated the kind of power flows which were critical during the February event, but in the face of the challenges discussed above, interregional planning should consider and plan for these kinds of events in the future. We encourage MISO to ramp up efforts in this regard and to include a discussion of such, including ongoing efforts to better account for these system challenges in interregional planning processes, in the final version of the MTEP21 Report.  

In addition to preparing for extreme weather events, it is important for MISO and its neighbors to expand the scope of their joint planning efforts to consider how interregional transmission solutions can assist with renewable integration. The shift to renewable energy resources is rapid and ongoing across the country, and geographic diversity of both generation and load will become even more critical in managing the variability on the system under higher penetrations of renewable resources. Not only can interconnected regions assist each other during extreme weather, but strong connections will be critical to cost-effectively maintaining reliability and energy and load balance in a high renewable future. We urge MISO to engage in coordinated system planning with SPP and PJM again soon and to expand the scope of those efforts to plan for transmission that can facilitate interregional support with renewable resource integration and during extreme weather. 

MTEP21 Should acknowledge that Future 1 is likely too conservative in its assumptions

The MTEP21 Futures stakeholder process was the most robust MTEP process ever. When we began the process in 2019, MISO and stakeholders used the best available information at the time to create the three separate Futures. Future 1 has been designed since its inception as the baseline of state- and utility-announced plans, with Futures 2 and Futures 3 showing a much more rapidly evolving energy system on both the generation and load sides. However, since the initiation of the Futures development, and stakeholders’ acceptance of Future 1 for the initial LRTP effort, Future 2 and Future 3 are beginning to look increasingly more likely as Future 1 rapidly becomes outdated and overly conservative. MTEP21 should recognize and discuss these ongoing dynamics to help ensure stakeholder buy-in as MISO LRTP and other reliability imperative efforts scale up and accelerate.  

Future 1 is the most conservative of the three Futures with the lowest amounts of fossil fuel retirements and additions of renewable energy resources. The Future relies on some utility integrated resource plans to forecast resource retirements and additions, but not all utilities in MISO produce publicly available IRP’s. Wisconsin utilities and many cooperative and municipal utilities across the MISO system, for example, have no legal obligation to conduct IRP processes, leaving a gap in MISO’s ability to reliably forecast the pace and extent of resource transition across its system. Major commercial and industrial customers have also announced significant procurements of renewable energy resources across the footprint, from Wal-Mart, Ebay, McDonalds, and more. None of those corporate climate goals have been adopted in MISO’s Future 1, again underestimating the speed and size of change in the system.  

Updated resource plans since the adoption of the current Futures also show existing resources retiring sooner than previously anticipated and a greater reliance on new lower cost generation resources. For example, Lafayette Utilities System (LUS) in Louisiana finalized its IRP in late 2020, after the window for stakeholder feedback to the MTEP21 Futures.^[6] The LUS IRP calls for an early retirement of the Rodemacher 2 coal-fired power plant and the addition of 300 MWs of new solar resources in Louisiana. Entergy Arkansas and Entergy Mississippi are also nearing the conclusion of their most recent IRPs that will likely show an early retirement of additional coal units plus rapid and significant addition of potentially thousands of megawatts of renewable energy resources that were not included in Future 1.  

New policies are also being adopted that were not considered in the MTEP21 Future 1. For example, New Orleans recently adopted its Renewable and Clean Portfolio Standard (RCPS) that requires zero emission generation resources by 2040. Also, FERC Order 841 will significantly increase the amount of energy storage and hybrid resources deployed in MISO compared to the zero megawatts of battery storage and just 2,400 MW of hybrid resources assumed by Year 10 in Future 1.  

In sum, over just the last 18 months the pace and scale of change across the MISO system has increased to a point where the assumptions driving change in Future 1 appear overly conservative. This is not to imply that projects and solutions identified in Future 1 analysis are not warranted, but to emphasize the urgency of approving the least-regrets projects produced by Future 1 and transitioning MISO’s focus to Futures 2 and 3. This urgency and MISO’s timeline for studying Future 2 and 3 should be discussed in the final MTEP21 report. 

MTEP21 should acknowledge and discuss how bolstering MISO’s transmission backbone now will solve queue problems and obviate the need for other projects. 

Section 2.2 of the MTEP21 Report outlines the current state of the queue in MISO, which is designed “to enable resource interconnections that will serve future energy and capacity needs.”  The report notes that:

• renewables account for over 80% of the current capacity in the queue;
• the queue “has experienced extremely high volume over the last several years as a result of growing interest in renewable technology that has benefitted from declining costs of technology, favorable tax incentives and regulatory treatment”;
• the current 79.5 GW of total capacity in the queue is down from the historic peak of 113 GW due to generation interconnection request withdraws; and
• the viability of interconnection projects “is often tied to the costs of network upgrades.”

This is indeed accurate and useful information.  However, the draft report is lacking important detail to paint a full picture of the current state of the queue. We suggest MISO make a  valuable addition to the report by including a thoughtful analysis that connects the dots between:

• the absence of recent construction of backbone transmission in the MISO footprint and the challenges faced by interconnection customers;
• the lack of transmission capacity and increasing economic congestion at numerous choke points in the system;
• the large and growing increases in assigned network upgrade costs for projects in the generation interconnection process, the vast majority of which are wind, solar and battery storage; and
• significant renewable project withdrawals from the queue largely due to the cost of these network upgrades making the projects not commercially viable.

In that the LRTP is designed to be a “response to the current and future resource evolution that has and continues to affect the bulk electric system” (section 3.1), this additional analysis would be helpful to move stakeholders towards a consensus on the need for the LRTP process to accommodate increasing demand for renewable energy and the backbone transmission it can facilitate.

MTEP21 should also discuss the potential for backbone transmission projects to obviate the need for ongoing spending on baseline reliability or “other” projects in the MTEP cycle. According to MISO’s 3rd Triennial Review of MVP projects in 2017, the MVP portfolio of projects eliminated approximately $300 million in future baseline reliability upgrades through MTEP17 analysis.^[7] Regional transmission projects designed using criteria similar to that used in the  MVP portfolio can help alleviate local reliability-driven transmission upgrades and ‘other’ projects that are typically included in MTEP appendices. More discussion on this dynamic--backbone regional projects reducing the need for (and expenditures on) local projects--is warranted in MTEP21 and would help secure stakeholder support for MISO’s ongoing efforts, including LRTP.  

Section 3.2 does not reflect our current understanding of the ongoing discussions regarding cost allocation. 

Section 3.2 of the MTEP21 Draft Report includes a section discussing Cost Allocation^[8] that does not reflect the current state of cost allocation discussions within the RECBWG. As an example, while the LRTP projects will likely look different than MVP projects, it is too soon to make a definitive statement as to the appropriateness of the MVP cost allocation methodology with respect to LRTP projects. Whether MVP serves as an effective model for LRTP projects is a question still being discussed in RECBWG meetings. To the extent MISO desires to make a statement regarding cost allocation within its MTEP21 Draft Report, it should not include definitive statements that are not ripe for inclusion in the draft report. As an alternative, identified strengths and weaknesses of various cost allocation methods may be more appropriate at this time.  

MTEP21 should continue to emphasize the cost of inaction on LRTP

During the ongoing discussions regarding LRTP, stakeholders continue to express concern that states are unable to afford the projected costs of the transmission build out envisioned by the LRTP process. These concerns persist despite numerous completed and ongoing analyses dedicated to identifying cost-effective solutions and emphasizing the reliability, resilience, and public health impacts of inaction. The data indicates that customers will ultimately save money and benefit from a more reliable and resilient system by building LRTP lines that are being identified and vetted using the best available tools and methodologies. MISO should continue to emphasize these points as appropriate in the MTEP21 report.  

It takes 8-15 years to build large-scale transmission. MISO must therefore plan the grid that we will need in 2035 and beyond, taking advantage of the best available information and most robust methodologies to inform the decision making process. This is precisely what LRTP is intended to do. If MISO does not plan now and we do not build the transmission grid that is needed in 2035, utilities will have a narrower set of solutions for the problems that we will face in 15 years. The “least cost” solution when selecting from hundreds of options will be much cheaper than the least-cost option when utilities are forced to select from only a few options, because they simply will not have the time to build the cheaper solution.  

MTEP21 should include a brief description in its cost-allocation section about how the LRTP Project will reduce the bills of electricity customers. For example, a 1.0 B/C ratio means that the economic savings provided by the project over only ⅓ of its expected life (20 out of 60 years) will pay for that line.  In turn, the economic savings for the subsequent 40 years will go directly into customers’ pockets. Moreover, when building its business case and looking for a project that meets a 1.0 B/C ratio, MISO is only calculating a small slice of the economic savings.  Not building LRTP projects with demonstrable economic savings means that customers are paying more for their electricity than is required. It is important for MISO to continue its efforts to be a resource to stakeholders and emphasize the reality that moving forward with robustly vetted LRTP projects is, in fact, a least-cost solution for consumers. Developing this collective understanding among stakeholders will ultimately be critical to the success of LRTP going forward. 

In sum, the Environmental Sector applauds MISO’s ongoing efforts to confront the challenges of the future head on and continue to prepare the system for the ongoing clean energy transition. It will take a 21st century grid to support the 21st century economy and we appreciate MISO’s recognition of that fact. We encourage MISO to consider these recommendations for the final MTEP21 Report to further bolster its efforts to serve as a resource to its stakeholders and develop a shared understanding of the challenges and opportunities facing the MISO system going forward. 

Thank you for the opportunity to comment. We look forward to our ongoing work together. 

MISO Environmental Sector   

In Section 1.1 MISO Overview, also provide expected generation at time of summer and winter peaks including derates for wind and solar capacity and EFOR for all generators.  Showing just nameplate capacity is misleading as the casual reader may thing MISO has a huge capacity excess.

Figure 1.1-3 title should be "New Line Miles by voltage".  Include table also showing the same data. 

There should also be a table and graph of existing line miles by voltage.