Missouri River Energy Services would like to thank MISO for soliciting feedback on this BPM and incorporating some suggested edits that have been received from stakeholders thus far. MRES agrees with MISO that the goal of the BPM is to provide consistency and clarity to the transmission determination process, and there has been progress toward that goal.
In an effort to further that goal, and rather than provide a set of redlines, below is a list of clean-up items and suggested edits that MRES would appreciate MISO considering:
- There should be an “s” added to “strive” in the second paragraph of section 1.2.
- MRES asks that MISO reconsider including state regulatory precedence in its considerations throughout the BPM being that FERC defers to the state’s determination, so long as that determination is based on the seven factor test. Although FERC has the ultimate authority on the transmission determination process, MRES is not aware of an instance where FERC has actually overruled a state determination. It is understandable that MISO would prefer not to have to reference state proceedings, however it should be allowed for an unregulated owner to do their own research and reference state precedence so that owners within a zone are treated comparably. If there is a comparability issue between states, that incomparability exists today for regulated entities, and unregulated entities should not be held to a different standard (FERC standard rather than a state standard) simply because they are unregulated.
- In section 2.2 item 4., the need for 2 years of historical data should be clarified for new/recently modified facilities. As written 2 years of data is “required”, however this conflicts with other sections of the BPM that suggest powerflows can substitute if actual flows aren’t available, such as when there is a new facility or the system configuration has changed.
- In section 3.1, MRES would ask that MISO include more direct references to FERC precedence for each factor. Currently there is only one reference for a single factor. MRES is not suggesting that the references be exhaustive, but it would add clarity for all involved if more references could be provided to help justify the changes from the currently implemented BPM to the proposed changes. The current BPM relied heavily on the Mansfield precedence (though it was not explicitly referenced) and it would be helpful if that reference was included.
- MRES would ask that MISO reword or expand on the explanation of normally open facilities. As written it is unclear if normally opens are generally considered in or out and what is meant by “respected”. MRES suggests the second sentence of the normally open description be - “a sufficient reason must be provided as to why and when the normally open element would needs to be closed…”
- MRES disagrees with Xcel’s comment about networked facilities needing to specifically show “benefit” to the rest of the system to be considered transmission. The term “benefit” isn’t found in the seven factors, as the criteria of the seven factors themselves establish if there is “benefit” to the greater system by determining if the facility serves multiple markets/customers/purposes, allows flows in multiple directions, etc. MRES does agree that the example of networked facilities is used too often in the explanation of the individual factors and does not provide clarity as it is generally accepted that networked facilities are transmission.
- Section 4.2 should be expanded to include all customers in a zone. It is not clear to MRES how other TOs in a zone are impacted by a prospective TO other than through their native load customers, and as such, all customers in a zone are impacted, not just the existing TOs.
Thank you for your consideration.
John Weber
Senior Transmission Engineer
Missouri River Energy Services
john.weber@mrenergy.com