DRAFT MTEP22 Report, Appendices Feedback

• Section 4.5, pg. 80
• All Madison Area Reactive Power Project references should be removed. Values including this project are inaccurate:
• Remove: "163 projects", "$1.3 billion", "117 projects", "163 projects", and "76 projects".
• Section 4.5 and 4.5.1

• The report did not reflect the edits made for SPM 3 as the snapshot of this data was taken at the end of July. All number and totals from 4.5 and 4.51 will need to be updated with results from SPM 3.

• Figure 4.5-2
• Remove value "55" from bar chart.
• Figure 4.5-3
• Remove value "33" from bar chart.
• Section 4.5.1, pg. 89
• Remove cancelled project "Madison Area Reactive Power Project".

Chapter 2 page 6 states “The potential for significant generation fleet transformation has prompted MISO to evaluate how system needs will change and how MISO might adapt its planning, markets, and operations to maintain reliability with aging and retiring units, higher penetration of variable resources, and new load consumption patterns.”

MISO needs to consider the effects of a future winter wind drought on the MISO system similar to the wind drought which occurred on January 28-30, 2020.  During this period wind output dropped to less than 1% of nameplate capacity for a period of 39 hours.

The question is:  Could MISO supply its load in the future under similar weather conditions, even if the wind drought was less severe? A 99% wind drought lead to the unavailability of 22 GW on wind in 2020; a similar wind drought today would result in the unavailability of 30 GW of wind. How would MISO keep the lights on if a wind drought occurred on a Future II or Future III system?

Consider the following (in addition to reduced wind output):

• Little or no solar output (Shorter daylight hours, low sun angle, snow covered panels, cloudy weather)
• Exhausted battery storage
• Increased load due to additional electric vehicle charging and electric heat load
• Reduced imports from other regions facing similar conditions

Chapter 2 page 1, combine “But the crucial question is whether the region will have enough resources with the capabilities and attributes that are needed to keep the lights on during the most challenging times, such as when load ramps up rapidly when the sun is not shining or the wind is not blowing, or when a large fossil power plant unexpectedly goes down. Those capabilities are measured in terms of “accredited” capacity, which reflects when resources are actually expected to be available, as well as how flexible they are to respond to fast changing grid conditions. And in the MISO Region, accredited capacity is declining because conventional resources that are highly available and flexible are retiring, and the renewables that are being built to replace them have significantly lower accreditation values due to their intermittent, weather-dependent nature. These challenges could be mitigated by building more new resources with high degrees of availability and flexibility, such as natural gas power plants, for example. However, efforts to build new gas plants in particular are facing headwinds from policymakers due to environmental concerns.”  Into one paragraph.  Then insert a new paragraph:

The situation in Illinois is particularly precarious.  In September 2021 Illinois passed the Climate and Equitable Jobs Act (CEJA), Public Act 102-0662.  This law calls for the closure of all coal plants in Illinois, except for Prairie State and Dallman by 2030 and for the closure of all natural gas plants over 25 MW by 2035.  This will result in the loss of 3359 MW of coal capacity in MISO Region 4 and 3785 MW of coal capacity in PJM Commonwealth Edison for a total loss of Illinois coal capacity of 7144 MW.  It would also result in the loss of 4430 MW of gas capacity in MISO Illinois and 11,262 MW of gas capacity in PJM Illinois for a total loss of 15,692 MW of Illinois gas capacity.  The total Illinois capacity loss would be 22,836 MW.  [Verify figures.]  This capacity loss, coupled with planned coal retirements in adjacent states, analyses have shown will cause voltage and transient stability problems in Illinois even with the planned large buildout of intermittent renewables in the area and with the LRTP Tranche 1 transmission lines in service.  MISO and PJM are performing studies of what transmission improvements that would be necessary to ensure system reliability in Illinois.  These transmission improvements would likely consist of synchronous condensers, STATCOMs and additional transmission facilities.  In any event, there will be a large shift in costs from the retired independently-owned generators in Illinois to Load Serving Entities in the AMIL zone in the form of increased transmission costs.

ENVIRONMENTAL SECTOR COMMENTS ON THE DRAFT MTEP22 REPORT RELEASED AUGUST 2022

The Environmental Sector submits the below questions and comments with respect to the MISO’s draft MTEP22 Report: 

“Age and Condition” projects represent an outsized proportion of projects and must be proposed further in advance of the need: 

MTEP22 continues the trend with the majority of the projects being “Other” project types, 47% of which are driven by “age and condition”. (See chapter 1, page 15.) While the Environmental Sector appreciates the need to occasionally replace some aging assets on an emergency basis, we continue to question why the majority of Age and Condition projects seem to be proposed on a  “just-in-time basis,” rather than coupled with more advanced planning. 

The majority of these Age and Condition projects will go into service in 2023 and 2024, thereby prohibiting the ability to look for more cost-effective solutions that might be identified if such Age and Condition Projects were part of more advanced planning. We don’t understand why the majority of Age and Condition replacement cannot be predicted or planned further in the future to allow for MISO to meaningfully incorporate these needs into the regional planning process, and we request that MISO take more action to address this ongoing issue. 

Page 11 of Chapter 1 indicates that “LRTP integrates with other shorter term planning processes to provide for long-range facility development needs,” pointing to Figure 1.2-3 to show how GIP, BRP, MEP, an LRTP planning processes relate with respect to planning horizons. However, there is no indication of how these processes are planned together in order to seek efficiencies in planning.  Order 1000 requires MISO to seek efficiencies by combining projects coming from bottom-up local planning that transmission owners do themselves, but we have expressed concern over many years that MISO is not actually doing this. And while MISO tells us it is doing this, there is a lack of transparency in the stakeholder process, and as such we’ve never heard of the identification of a more efficient project that replaces a TO identified project and/or GI network upgrade. At the very least, we believe that Age and Condition replacement projects are the very type that can serve as a good candidate for the more comprehensive planning that combines bottom-up local planning with the resolution of other needs that together create efficiencies that are otherwise missed in the annual MTEP process. With regard to addressing the transparency issue here, we request that MISO and the TOs present specific information about their consideration and discussions about potential replacement transmission solutions that might be more cost-efficient than bottom-up transmission projects.

More strategic use of the MTEP process is needed:

We appreciate that MISO is addressing the “dramatic shift in member utilities’ resource mix, increased electrification and increased incidence of severe weather events” through its “strategic vision” (see chapter 1, pages 8-9), but shouldn’t MISO’s routine expansion planning process also address those issues? 

For example, the Environmental Sector has been investigating ways in which to increase the capacity of the existing grid quickly to help deliver energy from existing generators and to remove QOL conditions that can limit the output of many generators. 

One option is for the installation of advanced conductors. When receiving a TO’s request for replacement of aged assets, is MISO asking the transmission owners to consider the use of advanced conductors rather than simply replacing like-kind with like-kind?  (Advanced conductors are no longer a “new and untested technology.”)  Similarly, when replacing substations and/or transformers, does MISO ask if the TO’s are sizing those facilities to allow for the use of advanced conductors that have a much higher capacity?  

Relatedly, while Grid Enhancing Technologies (GETs) are currently absent from MISO planning, these solutions can play an important role as the MISO grid approaches higher penetrations of renewable energy. This is increasingly important, as MISO’s recent Regional Resource Assessment (RRA) shows that, according to utility and state goals, reaching the 30% penetration highlighted in the RIIA report could be roughly 5 to 7 years away. Discussion of GETs should be part of MISO’s transmission planning efforts and MTEP reports going forward. 

This is also directly tied to how we can respond to resource adequacy concerns. As just one example, how does MISO evaluate whether it is cheaper to install such things as storage, synchronous condensers, advanced conductors, or dynamic line ratings? These technologies may prove to be more economic in the long run, rather than building expensive new generation that may be run only 10% of the year and whose fuel supplies could be constrained, all at a higher-than-needed cost to consumers.

Markets are also driving our changing resource mix:

The draft MTEP22 report states, “The regional Reliability Imperative is the shared responsibility of MISO, states, and utilities to address these issues in ‘minding the gap’ between today’s resource mix and our members’ state carbon-free goals.” (Chapter 1, page. 9.) Wind and solar are currently the least cost new generating source. While utility and state goals may be driving some of the change in the resource mix, so are the market and customer demands. This fact appears to be absent in this report, and we request MISO adjust its characterization that the evolving resource portfolio is driven only by policy goals. 

Increasing incidence of extreme weather should play a greater role in MTEP:

Cities experiencing a heat index greater than 105 degrees for more than 30 days a year will be widespread throughout MISO in coming decades unless there is a more rapid shift to non-carbon emitting resources. In this context, it is vital that this reality is a part of the transmission expansion discussion, and is considered an important driver. Delayed retirement of fossil fuel resources and delayed transmission expansion for zero emission resources will continue to drive increased extreme weather events, compounding the already daunting resource adequacy challenges forecasted over the next 20 years, not to mention the near term challenges that are already being observed. In addition to citing the effect, e.g. extreme weather, the MTEP report should also acknowledge the cause of these events, e.g. carbon emissions (See Chapter 1, page 9, and Chapter 2, page 1). We are beyond the days when such statements were considered controversial. 

MISO could help provide this context by also reporting on emissions reductions. The progress that the MISO footprint has made in this regard is important, but it should also be put into the larger perspective of planning for long-term resilience, and it may help better inform future MTEP processes. While we acknowledge that MISO may have emissions in mind when conducting its MTEP analysis, and it clearly analyzed the carbon reduction benefit of the recently approved LRTP Tranche 1 projects, the report in its current form does not adequately consider emissions reductions in planning in a material fashion.

Market Congestion Planning Study:

MISO Stakeholders have frequently raised the issue of congestion on the MISO system, and have recently highlighted the lapse in initiating a Market Congestion Planning Study (MCPS), which can help to identify projects that can address this congestion. We think it’s critical that this is remedied in the MTEP23 cycle to alleviate even greater congestion issues in future cycles.  MISO should begin another MCPS study as soon as practical and we will be recommending as much in our upcoming MTEP23 scoping comments. 

Transfer Capability Analysis:

MISO’s Transfer Capability Analysis provides valuable insight into Regional and Interregional Planning, but aside from presentations at the PSC, it is not included in MTEP reports. We believe it would enhance the final MTEP22 report to include the Transfer Capability Analysis, as well as Voltage Stability Analysis presented in the August PSC meeting. 

Portfolio Evolution:

Chapter 2 of the draft MTEP22 report appears to favor natural gas as the preferred solution to MISO’s current resource adequacy situation. While we hope that MISO does not have a real policy preference, we caution it from appearing to have one. MISO must remain technology neutral. Specifically, we believe that the following language on page 1 of Chapter 2 is especially problematic: 

But the crucial question is whether the region will have enough resources with the capabilities and attributes that are needed to keep the lights on during the most challenging times, such as when load ramps up rapidly when the sun is not shining or the wind is not blowing, or when a large fossil power plant unexpectedly goes down. Those capabilities are measured in terms of “accredited” capacity, which reflects when resources are actually expected to be available, as well as how flexible they are to respond to fast-changing grid conditions. And in the MISO Region, accredited capacity is declining because conventional resources that are highly available and flexible are retiring, and the renewables that are being built to replace them have significantly lower accreditation values due to their intermittent, weather-dependent nature.

These challenges could be mitigated by building more new resources with high degrees of availability and flexibility, such as natural gas power plants, for example. However, efforts to build new gas plants in particular are facing headwinds from policymakers due to environmental concerns. Moreover, regulations issued by the U.S. Environmental Protection Agency are contributing to the challenges the region faces by accelerating planned coal and gas retirements and driving new retirements. And to further exacerbate the situation, load is growing as the economy continues to rebound from COVID, and due to continued efforts to further electrify the transportation, buildings, and industrial sectors. Meanwhile, MISO’s Generator 2 Interconnection Queue currently contains very few resources with the kinds of capabilities and attributes that are needed to address challenges related to availability and flexibility.

We believe it is inappropriate to lean on only one potential solution, and that it masks both real causes and potential other solutions. MISO’s language in this section is concerning, as it suggests that renewables are the primary problem with regard to resource adequacy, without mentioning solutions such as storage and synchronous condensers and/or other proven technologies providing reactive power support. It is further puzzling that a few pages after stating that the queue contains very few resources with the ability to address resource adequacy, the report indicates that there is a significant amount of storage in the queue: 13.4GW, or 11 percent of the total (Chapter 2, pages 4-5). At the very least, this section of the report should be more neutral in its analysis by either including other potential solutions, such as storage, or by not singling out natural gas as the only resource with “high degrees of availability and flexibility”.

This language also ignores the fact that the PRA results were a planning problem. MISO and the utilities, had they had the right market signal and sufficient forward-looking planning, could have ensured more wind, solar, storage, transmission and other products providing needed attributes were online to meet the need. Also, MISO’s MTEP report is a transmission planning report and this section includes a wide range of other issues that go beyond transmission. The report should note more ways in which transmission planning can be part of the solution to resource adequacy needs. A more robust grid can provide sufficient transmission capacity to deliver generation capacity when needed, would add a great deal of geographic diversity for intermittent resources, and can address the north-south constraint that limited the ability of capacity resources in the South to address the shortage in the North. 

Page 6 of chapter 2 also discusses the PRA results without mentioning that one main reason for the past year’s result could be the absence of a sloped demand curve, nor does it mention that this is now a feature that MISO is pursuing. We believe a discussion of this is appropriate, especially given that other factors that led to the PRA’s result were also included, e.g. “faster-than-expected post-COVID lockdown load increase and delays in generation achieving commercial operation after having an executed GIA.” Inclusion of a sloped demand curve would have given the market a clearer indication that the resource margin was getting tight, and with such a curve, the market would have had more time to correct for it.

JTIQ Map:

Section 3.2.1 includes a map and table of JTIQ projects that includes transmission lines that are in fact part of tranche 1 of LRTP. We believe that this map and table should be updated to include only those projects that are currently part of the JTIQ portfolio. 

Interregional Planning with PJM:  

MISO says that it performs interregional planning with PJM. (p. 13.)  While we applaud MISO’s unprecedented Joint Targeted Interconnection Queue initiative with SPP, there currently is no meaningful interregional planning with PJM.  The pressing need for meaningful interregional planning is underscored but a number of facts including the “donut hole” in MISO, the 2022 PRA results, and the amount of imports from PJM during Winter Storm Uri.  The environmental sector strongly recommends that MISO initiate meaningful interregional planning with PJM that results in actionable projects across the PJM/MISO seam. 

Respectfully submitted on behalf of the Environmental Sector,

Natalie McIntire

Consultant for Clean Grid Alliance,

Environmental Sector PAC Rep

WPPI energy offers the following substantive comments on the posted draft MTEP22 Report:

• At p. 8/11 of Chapter 2, the report includes the following:

The OMS-MISO Survey shows fleet changes in the next 5-10 years shifting heavily toward renewables, Wind is at 15.5 accreditation and Solar is at 50% in the summer. As queue additions are not submitted much beyond 2025, the impacts observed are due more to unit retirement decisions. The increase in battery and hybrid units, nearly non-existent today, but projected to grow in the near future, indicates a changing dynamic in the MISO generation fleet—one emphasizing more flexibility and energy-shifting versus traditional fossil-based resources.

This language ties to Figure 2.4-5, which shows OMS-MISO Survey results by fuel type.  The figure is at variance with the text, however, in at least two ways.  First, the change in resource mix is plainly due both to coal retirements and increases in solar, with growth in solar a larger impact than reduction in coal.  Second, Figure 2.4-5 does not identify hybrid or storage resources, making it awkward and confusing to talk about increases in these resources in the context of the survey.  These resources are identified in Figure 2.4-6, pertaining to the RRA, however.  If MISO wants to talk about developments with storage (which we think would be a good idea), we suggest that this be linked to Figure 2.4-6 rather than 2.4-5.

• For completeness, we recommend that the discussion of the 2022-23 PRA in Chapter 3, which notes at p. 6/11 that the actual cleared reserve margin is 7.7% (UCAP), provide additional information on the other resources available for only part of the current Planning Year and thus not eligible for PRA participation (due to retirement within the year or commercial operation after June 1).  We recognize that these non-cleared resources do not have a must-offer obligation under MISO’s capacity construct, but they should be expected to contribute to resource adequacy nonetheless, and should be included in the discussion to provide a complete picture.

• The discussion of JTIQ beginning at p. 4/9 of Chapter 3 should note that some of the projects originally identified in the JTIQ study are no longer proceeding under the JTIQ process as they have been superseded by similar Tranche 1 LRTP projects.