In the August 31, 2022 meeting of the Planning Advisory Committee (PAC), MISO shared MTEP23 scope recommendations received to date from OMS, the Planning Subcommittee (PSC), and Subregional Planning Meetings (SPM).
Additional analysis requests for MTEP23 should be submitted via feedback by September 23.
WPPI endorses the comments submitted by Alliant Energy. We add that we support consideration over the next year of the following topics in transmission planning:
Alliant Energy believes MTEP23 should include study work focused on flow control solutions and how they can help manage flows across the system. LRTP Tranche 1, potential future tranches of LRTP projects and ongoing traditional MTEP projects are all helping to provide more system capability; a focus should now be placed on how increased capability, as well as existing capability on the system, can be better managed through flow control solutions.
In addition, Alliant Energy believes that HVDC should also receive focused study work as part of MTEP23. The drivers for the need to look more at HVDC include the potential for merchant projects to be connected to the MISO footprint as well as the potential for other HVDC solutions to help meet future system needs.
To the extent needed to fully address the items above, MISO should consider bringing in outside experts to discuss these topics who have more experience with their consideration in planning and application to address issues. Overall, the planning process should have more focus on alternative solutions that can either pair with traditional projects or applied standalone to help optimize the use of the transmission system.
ENVIRONMENTAL SECTOR COMMENTS ON THE SCOPE OF MTEP23.
The Environmental Sector appreciates the opportunity to comment on MISO’s study scope development for MTEP23. We strongly encourage MISO to leverage this scoping study to aid in more aggressively evolving to the grid of the future.
Long Range Transmission Planning (LRTP)
Given the urgency of the needs in MISO Midwest, we recommend MISO complete the studies for LRTP Tranche 2 as soon as possible and consider submitting it to the Board before the remainder of MTEP23.
Similar urgency exists to address the transmission needs in MISO South, thus any progress that can be made to accelerate study work on Tranche 3 and 4 should be a priority in 2023.
Given that LRTP is a 20-year-out study, the Environmental Sector asks that MISO run sensitivities that include partially deployed long-duration storage.
Tranche 2 should rely less on Future 1, and more on Futures 2 and 3.
Market Congestion Planning Study (MCPS)
We concur with Great River Energy/Southern MN Municipal Power Agency and Xcel Energy that an MCPS should, at least, be conducted in MISO Midwest for MTEP23. And again, transmission issues driven by economic congestion in the South should also be studied.
Inflation Reduction Act Implications
Storage Deployment - We concur with the munis/coops and TDUs that MISO should study the impacts of a more aggressive deployment of 4-hour energy storage resources resulting from the Inflation Reduction Act incentives.
Grid-Enhancing Technologies (GETs)
To drive down the costs for consumers, the Environmental Sector asks that MISO run sensitivities with a variety of forms of GETs installed on the existing grid. Providing data on the cost savings to state regulators will assist in their ability to mandate the installation of those devices within their respective jurisdictions.
Fast Ramping, Flexibility, Reactive Power, and Other Needed Ancillary Services.
MISO is now prioritizing its effort to identify a variety of needs on the grid including fast ramping, flexibility, and others beginning with its System Attributes workshop on September, 21st. We generally support this effort. Unfortunately, MISO has simply been going back to its 20th-century toolbox declaring that MISO needs new natural gas plants to fill those needs. MTEP23 should instead look to the 21st-century toolbox to identify new, and less expensive ways to fulfill those needs. It will take time for MISO to develop new market products that will incentivize provision of these new ancillary services; but there is no reason that MISO cannot now, in MTEP23, identify solutions to those needs and include them in Appendix A. Notably, as indicated by the results of the RIIA study, Transmission is one of the solutions that can help to meet some of these needs.
Run the Futures with a $0/MWh hurdle rate
The Environmental Sector requests that MISO, as a sensitivity, run the Futures in MTEP23 with $0/MWh hurdle rates for all neighboring regions including but not limited to SPP, PJM, AECI, and TVA. Modeling a $0/MWh hurdle rate may identify transmission constraints between the various regions that are masked by the hurdle rates that will be used in the primary MTEP23 model runs. This will allow a comparison of the runs with and without the artificial hurdle rates and the impact on the APC analysis and flow patterns. This approach will be particularly important in assessing beneficial solutions that should be evaluated with the generation mix in the high change case Futures. We note that SPP is completing this type of analysis as part of its 20-year transmission planning assessment, which provides an example for MISO to consider. We request that MISO eliminate any and all hurdle rates in this targeted study and MISO document the methodology of use of hurdle rates in the MTEP process.