During the February 9, 2021 Planning Subcommittee (PSC) meeting, MISO provided a review of the status of IR091. MISO shared a proposed timeline for submitting alternatives into the MTEP process. Stakeholder feedback is requested on the timeline presented.
Please provide feedback by February 23.
The OMS Transmission Planning Work Group (OMS TPWG) thanks MISO for allowing us to provide feedback on the MTEP Selection of Transmission Alternatives Integrated Roadmap Item (IR091). We are supportive of providing thirty days for stakeholders to provide non-transmission or transmission alternatives after MISO has posted the ongoing MTEP model on its CEII SharePoint. One solution could be that MISO post the MTEP models by May 1st and allow the stakeholders thirty days to provide alternatives by May 31st. However, if MISO posts the MTEP models after May 1st, the OMS TPWG recommends that MISO extend the deadline for transmission alternatives to thirty days after the date of posting. The OMS TPWG would appreciate it if MISO required the transmission owners to continue to update their project information, including the most limiting transmission system constraint on SharePoint prior to the second sub-regional planning meeting. This feedback does not constitute a position of the OMS Board of Directors.
Thank you for the opportunity to submit comments on the topic MTEP Selection of Transmission Alternatives (IR091). In summary, MISO’s footprint-wide MTEP process should remain consistent and aligned across all sub-regions and not deviate between the sub-regions due to specific stakeholder requests. Not only is consistency key, but the current MTEP process provides significant opportunity to propose timely and informed alternatives and deviation would be damaging to the process. ITC and Wolverine do not support any changes (changes that will only serve to extend or delay the current MTEP timeline) proposed under IR091.
In support of the change, one stakeholder suggests that there is insufficient time to study proposed projects and study alternatives. There is no reason stakeholders are unable to do so within the current timeline. In fact, most MISO transmission owners utilize base cases from the previous cycle and modify them as necessary to account for topology changes, generation, and load variations that have occurred since the previous MTEP cycle to perform annual assessment studies for the current MTEP cycle and meet TPL-001 compliance. This is a prudent and reasonable practice, especially compared with making an already long process, even longer. Furthermore, transmission owners submitting projects in MTEP must also identify whether they are utilizing MISO models for the MTEP submittals or if they have produced their own series of cases. If the latter, these cases must be provided to MISO for stakeholders. Stakeholders interested in evaluating Transmission Owners issues and projects with the possible interest in submitting alternatives have every opportunity to start their analysis at the beginning of the MTEP cycle using the same models that the transmission owners utilize and make the necessary modifications in order to identify the issues and identify any potential alternatives. To suggest the process is unfair or unreasonable disregards the available data, time, and resources available to do such study and alternative development within the existing timelines – just as in every other region of MISO.
ITC and Wolverine continue to support the May 31 deadline for submittal of alternatives proposed at the February 9 PSC meeting. By utilizing the models and data available at the beginning of the MTEP cycle, as mentioned above, the May 31 deadline provides Stakeholders 8.5 months to develop and submit alternatives while ensuring a level playing field for transmission owners and stakeholders and timely submission and approval of necessary transmission projects. In conclusion, the proposal assumes that a Stakeholder must wait for MISO to create the new current year MTEP models before they develop alternatives. That is simply not correct and does not reflect the practices of almost all other stakeholders and, certainly, all transmission owners.
Environmental Sector Feedback on MTEP Selection of Transmission Alternatives
Submitted 2/23/2021
The Environmental Sector appreciates the opportunity to provide feedback on this important issue. FERC Order 1000 clearly requires MISO to facilitate robust stakeholder involvement in the transmission planning process, noting that “absent timely and meaningful participation by all stakeholders, the regional transmission planning process will not determine which transmission project or group of transmission projects could satisfy local and regional needs more efficiently or cost-effectively.”[1] While our Sector generally agrees with MISO that 8.5 months is enough time for stakeholders to submit alternatives, we note that the current process must become more transparent and accessible if it is to satisfy the mandates of Order 1000.
The 8.5 month window is effectively cut to less than 5 months for stakeholders who do not have the resources or ability to comb through each individual Transmission Owner (TO) project submission made by the initial September 15th deadline. Members of the Environmental Sector are currently being blocked by MISO from accessing these submissions at all—a clear violation of FERC’s transparency requirements.[2] Even with access to that information, stakeholders would have to spend significant time digging through the submissions to get a holistic picture of what is being proposed. The projects are not presented in a public, aggregated format until the January Subregional Planning Meeting (SPM), meaning that many stakeholders effectively cannot begin considering alternatives until after that meeting. MISO should consider adding an earlier SPM or moving the January SPM to October or November for an initial public review of projects.
Under Order 1000, MISO’s Tariff, and its Transmission Planning Business Practices Manual, alternatives to transmission project proposals must be considered.[3] MISO stated at the February 2021 PSC meeting that it does consider alternatives to proposed projects—behind the scenes, in collaboration with TOs. However, this process does not appear to be publicly documented with any regularity. When our Sector reviewed the MTEP draft report last year, we found that “[o]ut of the hundreds of recommended MTEP20 projects, only 30 project descriptions indicate that any alternative solutions were explored. In addition, 33 project descriptions affirmatively state that no alternative solutions were considered at all.”[4] MISO then recommended approving ~96% of projects in MTEP20; we are unconvinced that TO-submitted projects are undergoing a robust iterative evaluation and selection process. To meet Order 1000’s requirements for transparency, MISO should provide a timeline of its internal alternative review process and more comprehensive public documentation at one of the SPMs of (1) which project alternatives were assessed and (2) the outcomes of those assessments and discussions with the TOs.
We also note that MISO’s Tariff directs the SPM participants to “[m]ake recommendations for a coordinated sub-regional Plan, after considering sub-regional and regional needs and alternatives, for the ensuing ten years, for all transmission facilities in the sub-region.[5] But TOs don’t typically share information on future project needs, including facility replacement plans, well enough in advance of the need for MISO and others to consider alternatives. Often information about projects that address local reliability needs, as well as replacements that address age and condition of existing lines, are only presented a few years or less in advance of the need for action, when there is no time to consider and implement possible alternatives. We request that MISO require TOs to share more information on their needs within the next 10-15 years, and we urge state Commissions to require this as well.
Greater transparency as requested in these comments would make MISO’s regional planning more effective and likely result in lower costs to consumers. It also would provide MISO stakeholders and FERC with a full view of the project submission, consideration, and approval process, and allow them to actually participate in and provide the full range of potential alternatives.
[1] FERC Order 1000, ¶ 152.
[2] See id. ¶ 150 (“Ensuring access to the models and data used in the regional transmission planning process will allow stakeholders to determine if their needs are being addressed in a more efficient or cost-effective manner”); see also Order 890, ¶ 471.
[3] See, e.g.,FERCOrder 1000, ¶ 81 (“Under the existing requirements . . . there is no affirmative obligation placed on public utility transmission providers to explore such alternatives in the absence of a stakeholder request to do so. We correct that deficiency in this Final Rule.”); MISO Tariff Attachment FF, I.C.9 (“Evaluation of Alternatives: When the planning analyses . . . identifies Transmission Issues, [MISO] will consider the inputs from stakeholders derived from the SPM processes, the inputs from the [PSC] and the [PAC], the plans of any [TO] with its own FERC-approved local planning process, and the MTEP aggregate system analyses against applicable planning criteria, in determining the solutions to be included in the MTEP and recommended to the [MISO] Board for implementation”).; MISO BPM-020, § 4.3.1.2 (“Once issues are identified, the planning process will explore alternative solutions to those issues with the objective of recommending the best overall solutions.”).
[4] Environmental Sector Feedback on the Draft MTEP20 Report, posted Sep. 2, 2020, available athttps://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/mtep20-draft-report-substantive-feedback/.
[5] MISO Tariff Attachment FF, I.C.2.c.i.a (emphasis added).
MRES makes no particular comments on the timeline at this point, but would like to stress that it is important to coordinate MTEP project alternatives with affected TOs (which may be more than just the project owning TOs) in a timely manner. This to understand any alternative MTEP projects that would be considered and provide relevant feedback. This is essential for purposes of NERC compliance, reliability, project ownership structure, construction timelines, etc.
Thank you for the opportunity to comment.
Alliant Energy supports the comments that have been submitted by DTE and WPPI. To meaningfully consider alternatives in the planning process stakeholders must have sufficient time and information. The current MISO process lacks in both of these categories. MISO should extend the time allowed to consider and provide alternatives as outlined in the comments provided by DTE. Further, more project information should be provided sooner in the planning process and include: the actual event causing the contingency, the initial mitigating step if N-1-1, the second event causing the second contingency, for Other projects, the specific TO planning criteria violated, the model year and season and a consistent project description proposed by the TO. Having appropriate time and information in the planning process to consider alternatives will help ensure that ultimately the right solutions are selected for customers.
Entergy Operating Companies Comments on the Proposed Timeline for Submitting Transmission Alternatives into the MTEP Process
February 23, 2021
The Entergy Operating Companies (Entergy) provide the following feedback on MISO’s proposed timeline for submitting alternatives into the MTEP process presented at the February 9, 2021 Planning Subcommittee (PSC) meeting, in connection with IR091.
Entergy supports the timeline proposed by MISO, but stresses that Transmission Alternatives must be submitted before the 2nd Subregional Planning Meeting, as later submission would introduce too much uncertainty in the transmission plan execution process. There must be adequate time to review alternatives, so all projects being considered by MISO should be presented by the 2nd SPM to allow for presentation of MISO’s recommendations at the 3rd SPM presentation.
These comments are submitted on behalf of the Missouri Joint Municipal Electric Utility Commission (MJMEUC).
MJMEUC supports the comments submitted by WPPI on this issue.
MJMEUC appreciates the opportunity to provide comments.
Consumers Energy agrees with and supports the comments submitted by DTE. Consumers Energy does not believe that the existing MTEP process is structured to provide a comprehensive and robust review of transmission alternatives. Consumers Energy requests that MISO consider the potential actions proposed in DTE’s comments to address the timeline concerns with the MTEP process and provide for a more robust and iterative review of transmission alternatives.
American Municipal Power supports DTE’s comments on this issue. American Municipal Power is interested in more overall transparency early on in the MTEP process so that transmission owner plans can potentially accommodate needs of non-affiliated LSEs in their service territory.
WEC Energy Group supports the comments submitted by WPPI in response to this request for feedback. We agree that much more information, such as key contingencies and modeling assumptions, is needed earlier in the process in order to develop meaningful alternatives.
MISO suggests that the timeline available to stakeholders wishing to submit alternatives is already quite long. We believe this case is somewhat overstated. In past years, although September 15 was the deadline for TO submission of projects, the project list was sometimes not posted for stakeholders until days or weeks later. In addition, the project posting itself often does not contain all the information necessary to fully understand the issue driving the project and meaningfully develop alternatives, such as key contingencies and model in which the issue was identified. Indeed, this information is often not fully provided at SPM1. Accordingly, while we agree that the timeline should, in principle, allow adequate opportunity for stakeholder input by May, more information will need to be provided earlier for the full 8.5 months to be available for alternative development.
Great River Energy supports the timeline presented in the IRO91 presentation and requests that any future discussion of MTEP alternative projects clearly and explicitly address the impacts to TO compliance and project ownership/construction.