PAC: MTEP Guiding Principles (20221129)

The FERC NOPR RM21-17-000 on “Building for the Future through Electric Regional Transmission and Cost Allocation and Generator Interconnection” places emphasis on the need to “conduct long-term regional transmission planning on a sufficiently forward-looking basis to meet transmission needs driven by changes in the resource mix and demand.”
Rather than relying on the threshold of Executed Agreements to inform the planning process, MISO should also consider including advanced, late-stage projects in the interconnection queue for a more holistic assessment of upcoming grid needs.
Times of great change require more inputs, scenarios, and consideration than what is currently granted. MISO can no longer afford to rely only on Executed Interconnection Agreements to prepare models for significant market trends. As mentioned in Invenergy’s filing in EL22-83-000, advanced projects like Grainbelt Express should be considered and accounted for in the planning process.
It is time for MISO to revisit their criteria for inclusion in long-term planning to expand the scope of possible projects being considered and better prepare the grid for the coming resource transition.
We encourage MISO to revisit their planning process to include late-stage, advanced projects as part of their transmission planning process.

The TDU Sector requests two important edits to the MISO Board of Directors’ MTEP Guiding Principles to reflect the critical goals of customer affordability and robust book end planning.  As the system continues to evolve, meeting carbon reduction objectives and maintaining reliability must be balanced with affordability.  The principles currently contain a gap related to this concept and the Sector requests that this is addressed with the current review through the suggested edit to principle 1 shown below. 

The TDU Sector also requests an edit to principle 5 to reflect the need to consider a range of system scenarios.  Analyzing a plausible range or book ends of future outcomes has always been important with system planning.  With the increasing pace of change, and future uncertainty, the Sector believes the use of a range of system scenarios is even more critical now and that this concept needs to be captured in the guiding principles. 

The Sector thanks MISO in advance for its consideration of these suggested edits which will help ensure the guiding principles provide the appropriate direction to achieve the right outcomes for customers and the grid.

Develop transmission plans that will ensure a reliable and resilient transmission system that can respond to the operational needs of the MISO region and that reflects affordability objectives of customers.

Make the benefits of an economically efficient electricity market available to customers by identifying solutions to transmission issues that are informed by near-term and long-range needs and provide reliable access to electricity at the lowest total electric system cost.

Support federal, state, and local energy policy and member goals by planning for access to a changing resource mix.

Provide an appropriate cost allocation mechanism that ensures that costs of transmission projects are allocated in a manner roughly commensurate with the projected benefits of those projects.

Analyze an appropriate range of system scenarios and make the results available to federal, state, and local energy policy makers and other stakeholders to provide context and to inform choices.

Coordinate planning processes with neighbors and work to eliminate barriers to reliable and efficient operations.

The Environmental Sector appreciates the opportunity to provide feedback regarding the MTEP Guiding Principles, and submits the following Board-level commentary: 

• Principle 3 should also include member resource plans in addition to member goals. Member resource plans are distinct from stated goals. There may be an incomplete overlap between the two, and without the inclusion of member resource plans, this principle risks creating an incomplete picture of what members are actually planning.
  
• We believe that there should be an additional principle focused on ensuring that the MTEP process considers energy and environmental justice. While it is true that states are best positioned to address energy and environmental justice, MISO can still better assist states by including energy and environmental justice issues in its transmission planning processes. For example, while MISO is primarily concerned with planning the endpoints of major transmission projects, the selection of those endpoints can still have a disproportionate effect on marginalized communities that could be avoided if such endpoints are adjusted. In the below redline, we offer a starting point as new Principle 4. It is our hope that discussion of this proposed starting point will lead to a principle that MISO can support.
  
  
• Principle 5 (Principle 6 in the below) should include the word, “multiple,” in “Analyze multiple system scenarios . . . .” This better reflects MISO’s current three-future planning process as well as MISO’s historic practice of multiple scenario transmission planning.  This addition also better emphasizes the best practice of evaluating the benefits of transmission additions under more than one potential future scenario.

An updated version of the MTEP Guiding Principles that incorporates the above comments would look as follows (additions in bold):

1. Develop transmission plans that will ensure a reliable and resilient transmission system that can respond to the operational needs of the MISO region.
   
   
2. Make the benefits of an economically efficient electricity market available to customers by identifying solutions to transmission issues that are informed by near-term and long-range needs and provide reliable access to electricity at the lowest total electric system cost.
   
   
3. Support federal, state, and local energy policy and member resource plans and goals by planning for access to a changing resource mix.
   
   
4. Ensure that transmission planning processes incorporate energy and environmental justice concerns by considering inequities faced by historically and currently marginalized communities, and by anticipating the creation of such inequities that may occur in the future. 
   
   
5. Provide an appropriate cost allocation mechanism that ensures that costs of transmission projects are allocated in a manner roughly commensurate with the projected benefits of those projects.
   
   
6. Analyze multiple system scenarios and make the results available to federal, state, and local energy policy makers and other stakeholders to provide context and to inform choices.
   
   
7. Coordinate planning processes with neighbors and work to eliminate barriers to reliable and efficient operations.

Appendix A of the MTEP Report comprises the transmission projects recommended to MISO's Board of Directors for review and approval. 

Thank you for considering our comments.