Website and Stakeholder Process Enhancements Workshop (20220222)

WEC Energy Group is not finding value in the "post only" agenda items and in some cases has noted that transparent stakeholder interaction is negatively affected.  During the March 9 meeting of the RASC, several "post only" agenda items received significant stakeholder discussion that would have benefited from separate agenda items (e.g. preliminary PRA data, out-year CIL/CEL, OMS-MISO survey).  While a page-by-page presentation of the posted material is not necessary, a high-level overview of the presentation followed by stakeholder discussion would have provided more structure and value than just an open-ended discussion of all "post-only" agenda items.  WEC Energy Group suggests that each "post-only" agenda item is taken up in succession, with each presentation given a high-level overview followed by stakeholder discussion.

WEC Energy Group also finds the 2022 meeting schedules of the MPEs lack structure and predictability.  We prefer a return to the traditional monthly "markets" week followed by a "planning" week.  If individual management plans do not require a meeting in a particular month, that meeting can be cancelled.  Cancelling meetings is much easier to accommodate than adding meetings.  Monthly meetings with "markets" the first week and "planning" the second week provides structure, predictability, and supports resolution of issues in a timely manner.

The Owners thank MISO for hosting the Stakeholder Process Enhancements Workshop and are supportive of MISO’s efforts to streamline the stakeholder process and make improvements to MISO’s website, agenda, and management plan templates.  The Owners look forward to gaining experience using the new tools and will let MISO know if we run into any issues with the newly implemented improvements.

The Owners are also appreciative that MISO has listened to feedback and will allow more time prior to stakeholder meetings for review of meeting materials that will be posted only and MISO’s willingness to have knowledgeable personnel available during meetings to address any stakeholder comments and/or questions.   In addition, the Owners greatly appreciate MISO’s willingness to open feedback requests on all proposed Tariff language revisions at both the lower-level and main parent entity stakeholder meetings prior to any FERC filings. 

With respect to the meeting schedule, the Owners are supportive of MISO adding meetings to the schedule as warranted and similarly canceling meetings when the agenda does not support a meeting. 

Consumers Energy appreciates the opportunity to provide feedback on the MISO Website Updates, Agenda and Management Plan templates and other potential enhancements related to the MISO Dashboard and Stakeholder Process Enhancements.

 Agenda and Management Plan Enhancements

CE shares other stakeholder concerns that the reduced frequency of Main Parent Entity meetings and change in format to include more post-only information limits the ability for stakeholders to become informed and engage in stakeholder processes to discuss and seek clarity regarding many MISO issues.

We do note that the recent March 9 RASC meeting format that shifted the Liaison Report ahead of the MISO post-only topics helped to provide an introduction and framework for some of the post-only items mentioned subsequently. This process did not flow as smooth on March 10’s MSC meeting. We recommend placing the Liaison Report ahead of the post-only items and have perhaps one slide dedicated to each post-only item main points for better information flow.

As both recent meetings have extended beyond the scheduled time, allowing more time for presentation and review of posted information may be required to better benefit both MISO and the stakeholder community.

CE appreciates a rolling 18 month management plan but has concern about irregular quarterly meeting dates replacing the previous Main Parent Entity monthly meeting format with occasional meetings being cancelled if lack of progress or topics for a given month. Several items that would normally be posted during a specific monthly meeting appear to be shifting and reducing consistency and timely resolution around an irregular meeting cadence.

Feedback Tool Enhancements

CE appreciates the website updates to the Feedback Tool Enhancements including MISO written response to comments.

MISO Dashboard

CE shares other stakeholder concerns regarding ability for stakeholders to submit issues of concern and the ability for stakeholders to collectively raise an issue’s importance for the greater community and not only issues that MISO deems worthy of pursuing.

As with the individual issue tracking and ability to follow with the improve website, we would request that an option be added to follow the MISO Dashboard webpage as a whole (similar to the “follow” button for a specific Stakeholder Feedback page) to see when new issues or information is added (as noted during the Workshop).

It would also be helpful if recent MISO presentations at MPE going forward are updated to reflect the “Explore” status rather than the previous “frame” and “evaluate” statuses, as this option seems to be removed from the current dashboard which provides more consistent ability to follow whether an “F” status refers to “Frame” or “FERC Filing”.

Executive Updates/Information Forum/Value Proposition

CE appreciated the January Executive Update for content and short presentation that showed a 6 month forward looking view. March’s Executive Update in contrast, seemed to provide a verbal overview of very similar content and did not include some items that were captured in previous Information Forum quarterly updates such as upcoming planned filings from MISO to FERC. This was raised as a topic at the recent MSC meeting and this information is of interest to stakeholders as well as the post only Value Proposition that could have also been included in the Executive Update. Please provide some idea as to what content could or should be included as these Executive Updates are continued.

WPPI offers the following feedback on the MISO Website Updates, Agenda and Management Plan templates discussed at the MISO Dashboard and Stakeholder Process Enhancements Workshop on 2/22/2022:

(1.)  Agenda: Items post only (although stakeholders are free to raise questions/comments)

• Thus far, WPPI has found this approach workable. In the case of some topics, this approach is saving time. However, in the case of other topics this approach may be taking a bit longer, because the subject matter expert is responding as questions/comments are raised vs. responding in a structured manner facilitated by delivering a presentation that may also preempt some of the questions/comments.
• A key to this approach is the subject matter expert (whether stakeholder or MISO) being present to address questions/comments. (In one instance, WPPI had a question that could not be addressed because no one was present at the meeting who could address it.)

(2.)  Feedback management

• In addition to posting MISO’s response to feedback in the feedback tool, it would be helpful also to post MISO’s response with the materials for the meeting at which MISO’s response will be referenced and potentially discussed further. 

Clean Grid Alliance appreciates the opportunity to provide feedback on MISO’s recent stakeholder enhancements. While we appreciate MISO’s goal of improving the stakeholder process and making more efficient use of staff and stakeholder time, we have serious concerns that the predominantly well-functioning stakeholder process was unilaterally changed without stakeholder input.  In many cases, the new process lacks transparency, accountability, and ability for stakeholders to actually provide input. 

We understand the goal of having “post-only” items for stakeholder meetings is to save time.  But instead, these presentations lack detail, and the benefit of clarification during a verbal presentation. Our experience so far has been that discussion and questions during this part of the agenda have not been as focused, or informative as occurred with presentations, and the agendas have not allocated adequate time for the discussions that did ensue.  In some cases, important and controversial topics have been put into these post-only agendas, or into the Liaison Report which has inappropriately limited stakeholder input, such as the discussion at the March MSC regarding having removed stakeholder input to the integrated roadmap process and renaming it the “MISO roadmap”. We agree with the point many stakeholders have made so far - that insufficient time is being allocated for stakeholder dialog, and hence preventing stakeholder input.   

MISO has completely removed the Roadmap prioritization process, once again limiting stakeholder input and transparency. It seems that MISO now plans to dictate the priorities based on staff and resource availability, eliminating the formal mechanism for the IMM and stakeholders to share what topics are of importance to their companies and organizations. Even though stakeholder input has always been advisory, the discussion among stakeholders had been helpful, and informative to both MISO and stakeholders. Opportunities for input and transparency are critical, and we recommend that MISO take more time to dialog with stakeholders about how best to make the process more efficient, while maintaining the key characteristics of a robust stakeholder process. 

MISO has eliminated opportunities for not just verbal feedback and discussion during meetings as described above, but written feedback as well. At the February IPWG, initially no feedback was requested on any topics, including Tariff or Business Practice Manual changes, but later was opened up on the Stakeholder Feedback Tool, after significant pushback from stakeholders. Written feedback was necessary, especially since several topics on the agenda were not discussed at all due to time constraints, given that a meeting typically taking 4-6 hours every one or two months was reduced to less than 2 hours after a 3 month gap in meetings. The shortened meeting time meant removing nearly all stakeholder discussion on the topics covered, and not including discussion topics that had been identified back in 2021 for discussion at the Feb 2022 meeting, including but not limited to, revisions to the A10 screening process.  

This is not a matter of “resistance to change” by stakeholders. Stakeholders from sectors that typically disagree with each other in meetings are very united in wanting to bring back the opportunities for stakeholder input and transparency that used to exist. Without a full MISO presentation, discussion, or ability for other stakeholders to review and digest those the overall comments, stakeholder meetings have been artificially cut short to prevent and in some cases eliminate, discussion, while written comments have also been reduced or eliminated in many cases. With some adjustments to this new process, progress can be made toward bringing back the robustness and transparency that previously existed with the earlier process. We encourage MISO to work collaboratively with stakeholders, which unfortunately was not done at all, prior to implementing these unilateral changes. 

MISO spoke highly of the “issue tracking tool” in the workshop, outlining the changes, and we agree this can be a useful resource.  We are concerned that some issues are not tracked at this point. If past issues from the last year or two, (particularly from the IPWG and PSC) are put into the tool, it could be helpful, and we look forward to the changes MISO mentioned would be complete in April. We would like to understand what issues are being put into the tool, and perhaps see a list of the from each stakeholder committee. MISO may feel an issue is not important to track, yet the entire stakeholder group may see value in it. MISO’s response to stakeholder written feedback, (when it is accepted) is provided online through the issue tracking tool, and the submitter must check back (at this point) to see responses. We agree with stakeholders who have suggested that links to comments and responses be provided in the meeting agenda as well as directly posted with the meeting materials. 

Many of the changes MISO has implemented are concerning as noted, including the fact that  stakeholders were not consulted or even provided advance notice that changes were coming. We encourage MISO to bring back a collaborative effort with stakeholders and adjust the recently implemented changes to reinstate transparency and stakeholder input, as two cornerstones of a robust and vital stakeholder process.  

Sincerely, 

Rhonda R. Peters, Ph.D.

Technical Consultant for Clean Grid Alliance