During the April 12, 2022, Planning Subcommittee (PSC) meeting, MISO discussed retired NERC standard FAC-013-2 and the BPM language related to the Transfer Capability (TC) Analysis. MISO is requesting Stakeholder feedback specifically on the following two questions:
Please provide feedback by May 16.
ITC Holdings thanks MISO for the opportunity to comment on the MTEP22 Transfer Analysis Scope Development (20220412) discussed at the PSC.
ITC appreciates the work MISO has done on its proposed transfers analysis . ITC is supportive of MISO's proposed plan to not complete transfer analysis as part of MTEP22.
Transfer analysis can be useful in illuminating system limitations that may appear during conditions of significant system stress. WPPI would support MISO performing transfer analysis as part of MTEP22 to the extent that the results of this analysis may be used to identify network upgrades that MISO may seek to implement. It appears that the LRTP study is presently the only MISO process that might lead to MISO seeking approval for such upgrades, and WPPI would support consideration in the LRTP process of upgrades that might alleviate significant near-term transfer limitations (that may be identified in this MTEP22 transfer analysis) while providing value over the longer term.
If MISO would not propose to use the results of such analysis to identify projects for potential approval, however, then it is not clear to us that there would be much point in performing the analyses.
If MISO does perform transfer analysis as part of MTEP22, we would suggest a focus on extreme conditions that may be accompanied by capacity emergencies, such as extreme cold weather in or adjacent to MISO, in which we might see, for example, high transfers into LRZ1, high transfers to LRZ 7, north-south or east-west flow similar to what occurred in mid-February of last year, or high transfers to PJM.