In the August 11, 2021 meeting of the Planning Advisory Committee (PAC), stakeholders were presented with proposed edits to Business Practice Manuals 020 Transmission Planning and 015 Generator Interconnection for Local Planning Criteria (LPC) enhancements.
Comments are due by September 1.
ENVIRONMENTAL SECTOR COMMENTS ON 20210811PAC AGENDA ITEM 3a TO LPC CRITERIA BMP-15 & BPM-20
The Environmental Sector appreciates the work that MISO has conducted over the past year and a half to eliminate the application of different Local Planning Criteria (LPC) in the Definitive Planning Phase (DPP) studies and the MISO Transmission Expansion Planning (MTEP) reliability studies. We understand that MISO feels some differential application of LPC may be justified given unique Transmission Owner (TO) systems. However, the Environmental Sector has demonstrated that a few LPC are being used to inappropriately shift costs for upgrading the regional transmission grid onto generator interconnection projects and that such differential application of LPC leads to unjust and unreasonable rates.
At the August 2021 Planning Subcommittee and Planning Advisory Committee meetings, MISO proposed changes to the BPM-15 and BPM-20. Overall, the Environmental Sector supports these changes. However, we believe that additional modifications are required to avoid unjust and unreasonable rates. To that end, we provide recommended changes to the proposed BPM-020 Section 4.3.2. These proposed redline changes will be submitted in a separate document so that the additions and deletions are visible.
Respectfully submitted,
MISO Environmental Sector