Stakeholders are welcome to submit informal feedback.
Please reference the Entity, Issue Number, if known, or topic.
Thank you.
The Environmental Sector appreciates the opportunity to provide these suggested changes to the PAC 2020-1 and PAC 2020-4 issue statements share in the presentation at the May 31 PAC meeting.
MISO’s SLIDE ON COORDINATED PLANNING (CPPTT): ISSUE PAC-2020-1
The only open item from the Coordinated Planning Process Task Team (CPPTT) was to develop a process to evaluate network upgrades from the queue process as Market Efficiency Projects (MEP)
Issue Statement as modified by MISO to address this specific topic:
Describe the process whether a Transmission Access Project may be evaluated as a Market Efficiency Project.
Clarify how base-cases are developed and used in transmission access studies, generator interconnection studies, and standard MTEP studies and how resulting network upgrades are considered as a Transmission Access Project or a Baseline Reliability Project.
New Transmission Access Projects are either Generator Interconnection Projects or Transmission Delivery Service Projects.
MISO does not anticipate having resources available to consider this issue until at least 2025 given current priorities of the Reliability Imperative.
Modifying this allows for the background and history to remain
We agree that the focus of PAC 2020-1 should be on defining a process for evaluating whether an identified Transmission Access Project also qualifies as a MEP, BRP, or MVP per the MISO project hierarchy. We offer a slightly edited version of the modified issue statement to update this PAC Roadmap issue.
New Transmission Access Projects are either Generator Interconnection Projects or Transmission Delivery Service Projects.
The remaining tasks under this issue relate to the need to
describe a process for evaluating new Transmission Access Projects to determine whether they meet the criteria for Baseline Reliability Projects, Market Efficiency Projects, or Multi-Value Projects.
clarify how base-cases are developed and used in transmission access studies, generator interconnection studies, and standard MTEP studies and how resulting network upgrades are considered as a Transmission Access Project or a Baseline Reliability Project.
MISO does not anticipate having resources available to consider this issue until at least 2025 given current priorities of the Reliability Imperative.
MISO’s SLIDE ON CONSOLIDATED PLANNING (CP) ISSUE PAC-2020-4
There is general agreement that Long Range Transmission Planning produces regional solutions, including consideration of Avoided Transmission Investment
Issue statement as modified by MISO:
MISO will review how to enhance our process to show how alternatives are identified for robust planning that result in a system that more efficiently meets the various needs on the system including age and condition replacement projects.
MISO does not anticipate having resources available to consider this issue until at least 2025 given current priorities of the Reliability Imperative.
Modifying this allows for the background and history to remain
There were two primary components to Consolidated Planning neither of which is addressed by MISO’s proposed modified issue statement:
Holistic Planning: Ultimately the greatest benefits to consumers would be the implementation of a Consolidated Transmission Planning process, where some or all of the existing planning silos are combined so that multiple transmission needs (reliability, economic, interconnection, replacement of aging assets etc.) can be considered at the same time. This has greater potential to ensure comparable treatment and to increase MISO’s ability to identify the most cost effective transmission and non-transmission solutions to the region's existing and future transmission needs. While LRTP accomplishes part of this, there are limitations, including the following
a. LRTP requires a portfolio;
b. MISO has not committed to completing LRTP on a frequent basis; and
c. LRTP does not actually consolidate the separate planning processes; at most it anticipates some of the needs that would likely be identified in various processes.
SPP is currently trying to design a holistic planning process and perhaps MISO could learn from the SPP efforts.
Evaluation of Alternatives to Aging Assets: First, MISO needs to require that the transmission owners provide additional information about their aging assets and asset renewable plans (10 or so years out) so that such information can be considered when MISO considers alternatives in the MTEP reliability modeling. Second, based on utilities’ asset renewal plans, MISO can determine if there are available alternatives that are more cost-effective than Other and BRP lines being proposed during the bottom-up process.
MISO’s proposed re-write of the Consolidated Planning issue focuses solely on process (explaining better how alternatives are evaluated) versus actually improving the planning processes. We suggest the following language instead for the issue re-write:
MISO will review how to enhance its process to show how alternatives are identified for robust planning that result in a system that more efficiently meets the various needs on the system including age and condition replacement projects.
MISO will consider implementation of a Consolidated Transmission Planning process, where some or all of the existing planning silos are combined so that multiple transmission needs (reliability, economic, interconnection, replacement of aging assets etc.) can be considered at the same time.
MISO will consider how to require or encourage transmission owners to provide additional information about their aging assets and asset renewable plans (10 or so years out) so that
such information can be considered and enhance MISO’s planning process when it identifies alternatives in the MTEP reliability modeling.
MISO can determine if there are available alternatives that are more cost-effective than Other and BRP lines being proposed during the bottom-up process including those driven by utilities’ asset renewal plans.
MISO does not anticipate having resources available to consider this issue until at least 2025 given current priorities of the Reliability Imperative.
Respectfully submitted on behalf of the Environmental Sector,
Natalie McIntire
Senior Advocate
Sustainable FERC Project
This feedback is submitted on behalf of the Missouri Joint Municipal Electric Utility Commission d/b/a Missouri Electric Commission. The topic is the Ramp Administration Day-Ahead Interchange Schedules issue presented by Manitoba Hydro at the May 23 RSC meeting. From the Missouri Electric Commission's experience, Day-Ahead ramp is a chronic issue for its operators trying to export from MISO. The Missouri Electric Commission would fully support an improvement in that process like what was suggested in Manitoba Hydro's presentation at the May 23 RSC meeting.