PAC: BPM-015 Updates for LRTP integration in GI (20221019)

Transmission Owner Sector Comments on Proposed Edits to BPM-015 Section 6.1.1.1

November 4. 

In the October 19, 2022, meeting of the Planning Advisory Committee (PAC), MISO presented proposed updates to BPM-015 Section 6.1.1.1, to account for Long Range Transmission Planning (LRTP) integration into Generator Interconnection, and Stakeholders were invited to review and provide feedback, which the MISO Transmission Owner Sector (Owners or TOs) provides below for MISO’s consideration.

The Owners do not support the changes proposed at the October PAC meeting because, as described further below, given that discussion with TOs and ICs regarding in-service dates of network upgrades and interconnection projects would be the same with LRTP as with any network upgrade included in an MTEP Appendix  the proposed additions do not provide any clarity to how LRTP projects will be considered relative to constraint mitigation (the subject of BPM-015 Section 6.1.1.1),.   Instead, the proposed revisions introduce confusion to the process.

• The language “including review of Appendix A” does not add anything to the existing language, which broadly states that “MISO will check the MTEP appendices” to determine whether a solution to a constraint requiring mitigation in the DPP has already been identified, in LRTP or otherwise, or if the development of a new solution is required.  There are no proposed revisions to the language in this section that addresses later approval of a project that has been identified as necessary mitigation in a DPP study.   
• The proposed “like for like” qualifier of transmission projects beyond the MTEP5 year out LBA dispatch case is likely to cause confusion in the identification of an appropriate solution, it may limit the consideration of better alternatives, and it does not add anything to the clarity of the current language.

Given that discussions regarding the ability of a network upgrade to mitigate a constraint identified in a DPP study would be the same with LRTP as with any network upgrade, the Owners do not feel that it is necessary to include language to clarify the treatment of project beyond the bench case, however, if MISO feels that such clarification is necessary, the Owners suggest the following language as a more straightforward approach to capturing MISO’s intent to consider LRTP projects as potential mitigation in the Generator Interconnection Process:

To mitigate a constraint identified in a DPP study, MISO will check the MTEP appendices and discuss with the impacted TO(s) to determine if there already exists a planned project which will alleviate the constraint.  If there is no such planned or proposed project, MISO will work with the impacted TO(s) and ICs to identify a solution consistent with baseline planning solution development described in Sections 4.3.1.2 and 4.3.1.3 of BPM-020, subject to the concurrence of MISO, the TO(s) and ICs.  If a project(s), including approved LRTP projects with in-service dates beyond 5 years, resolves the constraint, and that project(s) is approved by the Board within (1) calendar year of the GIA executed or execution of an amendment thereof, then the IC will not be responsible for upgrade(s) that would resolve the constraint, but the MTEP project will be included as a GIA contingent facility.  If that project(s) is not approved within one (1) calendar year of the GIA execution or execution of an amendment thereof, the IC will be responsible for those transmission upgrade(s).

In addition to clarifying the intent of the revision, the language suggested above would address the issue raised in the discussion at the PAC relating to the unintended consequence of the proposed language applying to all projects going forward.

The Owners support the proposed language referring to the inclusion of MTEP projects as GIA contingent facilities.

WPPI shares the concerns expressed by some other stakeholders that the 'like for like' criterion could lead to construction of upgrades that are not required to address constraints.  We encourage MISO to continue thinking about how to guard against this outcome.

ENVIRONMENTAL SECTOR COMMENTS ON PAC AGENDA ITEM:  INTEGRATION OF LRTP INTO DPP MODELS

 The Environmental Sector appreciates the opportunity to provide comments to the Planning Advisory Committee on the integration of LRTP into DPP models and strongly opposes MISO’s edits to BPM 15 § 6.1.1.1

 MISO has proposed edits to Generator Interconnection BPM 15 § 6.1.1.1 that would put a new, restrictive “like-for-like” requirement to incorporate any MTEP upgrades into DPP models. See:  https://cdn.misoenergy.org/20221019%20PAC%20Item%2005d%20BPM%20Language%20Updates%20to%20Account%20for%20LRTP%20Approval626688.pdf

The process today works as follows: 

 Generator Interconnection DPP studies that start in January begin with updated MISO transmission models that include all the latest approved MTEP expansion plans from the December MISO Board of Directors’ approval cycle. 

 Rarely, however, do DPP study cycles begin in January.  They typically start later in the year with the previous December updated MTEP transmission models, which can quickly become obsolete once December arrives for a new MISO Board approval cycle. In some cases, two or more approval cycles can pass before a DPP cycle is completed, especially when affected systems delays (beyond MISO’s control) impact DPP timing. 

 Updated MTEP modeling changes are not incorporated in existing DPP studies as a general practice, but interconnection customers can request that lines impacting their projects be inserted into the outdated models used in their DPP studies, which eliminates redundant projects from being required through the DPP. Typically, adding an MTEP upgrade in the DPP model can result in resolution of the original constraint, allowing for removal of a DPP-required upgrade that addresses the same constraint. BPM 15 § 6.1.1.1 governs this process, and has historically helped in preventing redundant infrastructure. 

 Note that building redundant upgrades to address the same constraint—in addition to wasting consumers’ money--could also end up reducing the benefit-to-cost ratio of future MEPs, LRTP, TMEP that may more efficiently serve multiple needs.

 New “like-for-like” requirement: 

 But now, MISO is proposing a new “like-for-like” requirement that will eliminate these efficiencies. MISO proposes that only upgrades, which are exactly the same in both MTEP and DPP, be eliminated as an upgrade requirement for the interconnection customer. (The existing process focuses on performance of the upgrade --elimination of the constraint--while the new process focuses on MISO’s definition of the upgrade.)   

 Impact of the “like-for-like requirement”:

 We applaud MISO’s interconnection queue improvements that will result in a 377-day DPP phase.  This means, starting with the 2024 DPP cycle, at most, one new MTEP cycle will be absent from the DPP models, assuming there are no delays in the study process.  But even one MTEP cycle could result in costly, redundant upgrades.  Also, DPP cycles before 2024 could omit multiple MTEP cycles and are, therefore, especially vulnerable to creating redundant infrastructure that will be expensive for consumers. 

  MISO has stated that the new like-for-like process is necessary because studying the impact of approved LRTP lines in DPP cycles prior to 2022 (when LRTP is fully implemented in DPP models) will create too much work for MISO staff with all the combinations and permutations available. However, MISO is tasked with ensuring rates are just and reasonable, and redundant and/or higher cost Network Upgrades resulting from a “like-for-like” requirement will not meet that standard. If MISO anticipates significant additional work, perhaps consultants can be hired to temporarily take on this work so as to continue a valuable practice that ensures efficiencies in the transmission system build out.  

In sum, we urge MISO not to adopt the like-for-like process as proposed because it would result in expensive, redundant upgrades.  Instead, MISO should look for other solutions to its staffing shortage, a solution that would not result in unjust and unreasonable rates.

Clean Grid Alliance Comments on the Integration of LRTP into DPP Cycles

November 4, 2022

Clean Grid Alliance appreciates the opportunity to provide comments to the Planning Advisory Committee on the integration of LRTP into DPP models. We have concerns about MISO’s proposal to create a very restrictive “like for like” criteria going forward in perpetuity, applied to all mid-GI process approved MTEP transmission expansion plans, preventing those plans from lowering costs to interconnection customers. This will result in higher cost Network Upgrades being assigned to generators. Very rarely will a like for like criteria ever be met, and therefore this proposed departure from existing practice will lead to unnecessary overbuild of the MISO system and higher costs for generators. Just as DPP projects mitigate non-DPP transmission expansion for reliability, MEP, and other project needs, resulting in removal/fewer/lower cost non-DPP transmission projects, so do non-DPP transmission expansion projects also impact DPP constraints and lower costs. Typically this occurs by lowering Generator Interconnection Network Upgrade costs as a result of shifting where an original DPP constraint is located to a new, lower cost, location, but not completely eliminating upgrade costs for DPP generator interconnection, as “like for like” will require. There has long been some balance in offering efficient solutions with respect to the two processes, but this new proposed “like for like” criteria only for BPM 15 will significantly disrupt that balance and result in unnecessarily higher Network Upgrade costs for generators in perpetuity, impacting all future DPP cycles. While MISO has stated this change is needed because it does not have resources to use the existing/current process to integrate LRTP projects into pre-2022 DPP cycles, it has remained silent in regard to any need for this proposed change to be ongoing and permanent in perpetuity, as the proposed BPM language specifies. Clean Grid Alliance opposes application of a "like for like" criteria in perpetuity, and asks that MISO provide additional information on the need for this proposed change at all. 

We agree with other stakeholders that the "like for like" language is unduly restrictive and should be removed from the proposed language.

To address MISO's concerns of "analysis paralysis" at the 10/19 PAC, we have the following feedback:

• MISO is obligated to evaluate solution alternatives to ensure duplicative GI Network Upgrades are not built alongside planned, approved MTEP projects. Not considering alternatives diminishes the benefit and need of the approved MTEP projects, overbuilds the system, and drives up avoidable costs for GI customers.
• If MISO is overwhelmed by the number of alternate solution evaluation requests, a replacement process must be given to GI customers to show their Network Upgrades are unnecessary when accounting for approved projects. We would be happy to show supporting data and evidence from consultants and internal studies that mirror the work MISO is doing today on solution alternatives.

WEC Energy Group agrees with the language in BPM-015 Sect. 6.1.1.1 that requires MISO to discuss with the applicable Transmission Owner to determine if a planned transmission project (including approved MTEP Appendix A projects) beyond the 5-year out bench case will alleviate a constraint identified in the DPP studies.  We disagree that such a transmission project must be a "like-for-like" in order to be considered as a replacement for a DPP transmission upgrades to mitigate a constraint.

"Like-for-like" is very subjective language and not common vernacular among transmission planners.  Either a planned transmission project will alleviate a constraint or it will not.  WEC Energy Group recommends striking the "like-for-like" language such that the BPM reads, "To mitigate a constraint, MISO will check the MTEP appendices, including approved Appendix A projects with in-service dates beyond the 5-year out bench case, and discuss with the impacted TO(s) to determine if a planned transmission project will alleviate the constraint."