In the June 22, 2022 meeting of the Planning Advisory Committee (PAC), stakeholders were invited to submit feedback on Adjustment to Att. EE for Authorized Requestors.
Comments are due by July 6.
The OMS Transmission Planning Work Group (TPWG) is supportive of tariff changes that increase the transparency of the transmission planning process. The changes proposed by MISO are beneficial to the transmission planning process as they correct an unintended issue in the tariff that complicates the State Regulatory Authorities sector’s ability to collaborate. These proposed changes will allow members of our sector to work together once they have executed the appropriate NDAs regardless of the pathway they have chosen to do so (i.e., as an Authorized Agency or Authorized Sector NDA).
This is OMS work group feedback and does not represent a position of the OMS Board.
Transmission Owners Sector Feedback on Adjustment to Attachment EE for Authorized Requestors
July 6, 2022
In the June 22, 2022 meeting of the Planning Advisory Committee (PAC), stakeholders were invited to submit feedback on proposed Adjustment to Attachment EE for Authorized Requestors, and the Transmission Owners Sector (Owners or TOs) provide the following comments for MISO’s consideration.
The TOs are concerned with the proposed removal of the notice requirement; especially without any context regarding the need for making this change, elimination of the notice to the Affected Participant Owners is unreasonable, as Owners should reasonably be entitled to the notice that MISO is planning to eliminate in its proposed revisions:
• Eliminate the additional notice requirement regarding the existence of consultations between agencies already authorized to access information
If this change is important to MISO, the Owners would be interested in better understanding the types of consultations MISO are trying to facilitate with these changes, as we do not currently see the need to remove the notice requirement that this disclosure is taking place without more context regarding the intent of the consultation. Although there was already notice that the Authorized Requestor will have access to the information, that notice is insufficient for further use of the information in consulting with an Authorized Agency. The owner of the information has the right to know that its information is being used in further consultations with other parties and that the original notice is not sufficient to permit that discussion as relating to a legitimate and permissible business purpose.
The Environmental Sector submits these brief comments in support of MISO’s proposed updates to Attachment EE of the tariff. Allowing consultations among Authorized Requestors from different entities is reasonable if both Requestors have received access to transmission planning information and data. The tariff edits proposed will help improve stakeholder communications and engagement on the issues and avoid confusion between MISO and its stakeholders.
We also believe MISO’s proposal for additional time to confirm the identities of authorized persons is reasonable, particularly in light of the proposed elimination of additional notice requirements regarding consultations between Agencies.
Thank you for the attention to this issue and we encourage you to move forward expeditiously with filing these proposed updates to Attachment EE at FERC for approval.