Informal Feedback (202309)

Environmental Sector comments to PAC/LRTP re: HVDC and 765 kV consideration

The Environmental Sector submits these informal comments requesting an update on MISO’s consideration of 765 kV and HVDC transmission technologies and to encourage MISO and stakeholders to move forward with a dedicated process to evaluate these technologies, develop methodologies for quantifying the range of benefits they might provide, and incorporate their consideration in MISO’s ongoing LRTP transmission planning process. 

The Environmental Sector believes all potential solutions to system issues identified through LRTP reliability modeling should be objectively considered and weighed against other potential alternatives. To reiterate the position expressed by our sector and others during the June 1st Planning Advisory Committee meeting: robust analysis should drive the identification of solutions. To this end, MISO and stakeholders must ensure that LRTP modeling inputs - particularly those representing the characteristics of various technologies under consideration - accurately and holistically represent both the costs and potential benefits each technology provides to the system.

When comparing potential solutions, all attributes – and therefore all potential costs and benefits of a particular solution – should be included when weighing solutions against each other. In the case of HVDC, and in particular VSC HVDC, the ability to provide a level of dispatchability, voltage control, reactive support, grid-forming capabilities, black start, reactive power, and other attributes must be included in any cost/benefit analysis of HVDC technologies compared to alternative solutions. At a time when MISO is actively raising concerns about the need for various system attributes to maintain reliability on a system heavily dependent on renewable energy resources, it is counter-intuitive to ignore a technology’s ability to provide such attributes as outside the scope of MISO’s LRTP process. 

MISO, in collaboration with stakeholders, must define a methodology that can holistically account for the attributes of various reliability solutions, provide a basis for quantifying the reliability and resiliency benefits of those attributes, and ultimately provide a pathway for stakeholders and MISO to identify with confidence the solution that provides the highest level of net benefits to the system.

Now that MISO has progressed to building the models for the Tranche 2 analysis, it is time to update stakeholders on where the consideration of HVDC and 765 kV technologies stands and identify next steps towards a fair and holistic methodology for evaluating them as solutions in the LRTP Tranche 2 process. 

Thank you

Environmental Sector

Following the August 31 LRTP Workshop, the TDU Sector has the following comments on the Tranche 2 study effort:

Resource-mix Sensitivity

• The TDU Sector has repeatedly called for the LRTP study process to include robustness analysis, particularly to assess the impact of changes to the assumed resource expansion.  Perhaps most notably we made such points in our response to the Future 2A feedback request from the November 2022 Planning Advisory Committee (https://www.misoenergy.org/stakeholder-engagement/stakeholder-feedback/2022/pac-futures-f2a-expansion-results-20221129/).  MISO has not yet clearly and meaningfully responded to this request. 
• We are aware that MISO’s IMM raised similar concerns in its Recommendation 2022-4, included in the 2022 State of the Market Report (https://www.potomaceconomics.com/wp-content/uploads/2023/06/2022-MISO-SOM_Report_Body-Final.pdf), to which we expect MISO will respond by October per Section 57.3 of MISO’s tariff.  We are aware that MISO typically gives a presentation to the Market Subcommittee (MSC) in which it responds to IMM recommendations, something that appears on the current MSC Management Plan for November.  Acccordingly, we would ask MISO to clarify this fall whether and how it plans to test the sensitivity of its LRTP Tranche 2 results with respect to alternate resource-expansion assumptions. 
• As both the TDU Sector and MISO’s IMM have proposed broadly similar alternative resource expansions, it appears MISO could address both recommendations simultaneously.  Given that this topic is within the subject area of the Planning Advisory Committee (PAC), and not the MSC, we would ask that this occur at a PAC meeting or LRTP Workshop. 
• We are aware that Aubrey Johnson addressed this topic briefly at the August 31 LRTP workshop, but his description of MISO’s intentions was not sufficiently detailed for stakeholders to understand what MISO plans.

Benefit Metrics

• The TDU Sector articulated concerns about MISO’s LRTP benefit metrics during the Tranche 1 process, notably our substantive comments on the MTEP21 Tranche 1 Addendum (https://cdn.misoenergy.org/MTEP21%20LRTP%20Tranche%201%20Portfolio626133.zip).  In particular, we noted that use of different reference cases for different benefits raises issues around whether the different benefit estimates are additive, and have called for use of a reference case that best represents how the system would most likely develop absent a new LRTP portfolio.  We don’t believe MISO has ever meaningfully addressed these concerns.
• MISO’s IMM raised similar concerns in the 2022 State of the Market Report and recommended changes as part of Recommendation 2022-4.
• Given significant overlap between the benefit-metric concerns our sector has raised and those included in SOTM Recommendation 2022-4, it appears MISO should be able to address both sets of concerns simultaneously.  We ask that this occur this fall at either PAC or an LRTP Workshop.

Stakeholder Process

• The sector appreciates MISO’s efforts to prepare LRTP Workshops to address ongoing work on Tranche 2.
• We note, however, that the 2023 workshops to date have mostly not included enough time for a full airing of questions around and discussion of the issues presented.  This is a source of significant frustration for stakeholders, which—we expect—makes these workshops somewhat unpleasant for MISO as well.  Stakeholder process is unavoidably messy and time-consuming, and we expect MISO may believe its time is better spent on LRTP analysis than on preparing for and participating in stakeholder workshops, but we believe the best course of action is to devote the time and effort to accommodate a full airing of views and questions around MISO’s work.
• It appears to us that this will require longer and more frequent workshops than MISO has planned, particularly given MISO’s public target of mid-2024 approval of a Tranche 2 portfolio.
• We appreciate MISO’s posted LRTP Tranche 2 FAQ document ((https://cdn.misoenergy.org/MISO%20Long-Range%20Transmission%20Planning%20LRTP%20Tranche%202%20FAQs.pdf627648.pdf).  We ask that MISO update this document to indicate how additional questions may be submitted to MISO (e.g., via lrtp@misoenergy.org) and continue to update with additional material questions submitted and accompanying MISO responses.