PAC: Inactive Issue Proposal (20230308)

The TDU Sector offers the following comments on the topic of inactive issues:

• PAC issues should be closed only through explicit action of PAC;
• MISO having “other work on the Reliability Imperative (e.g. LRTP)” could be a basis for placing an issue in inactive status; it is not obviously a basis for closing an issue;
• It appears that consideration of the two issues raised in Natalie McIntire’s presentation has not run its full course, and thus that these issues are not obvious candidates for closure;
• Accordingly, we are inclined to believe that the issues should remain in inactive status to the extent that MISO and stakeholders are not currently prepared to commit resources to address them, though they could be closed by action of PAC;
• As Natalie’s presentation noted, LRTP is at least partially responsive to the issues in question, and we believe JTIQ (and potential expansion of JTIQ to PJM) may also be;
• It may also be possible advance the issues in question through modification of the LRTP or JTIQ initiatives by, e.g., better accounting for other types of needs when considering projects;
• We encourage proponents of these issues to consider proposing specific approaches to address these issues, either within or outside of LRTP and JTIQ initiatives, and even where MISO staff do not show current interest in devoting resources to these issues.

TO: MISO Stakeholder Engagement                                                                                                        May 12, 2023

FROM: Public Consumer Advocate Sector

RE: Closing of Coordinated & Consolidated Planning Issues (PAC2020-1 and PAC2020-4) 

As we all know transmission costs are growing as a percentage of customer bills, and according to the U.S. Energy Information Administration, the trend is likely to only grow given the large amount of transmission development necessary to enable clean energy project development so the country can meet emissions reduction goals. 

MISO’s processes can significantly affect the size of the rate impact from transmission development in several ways, such as by fast-tracking the approval of certain transmission projects and coordinating cost-sharing for those projects so that the rate impact is spread across more of the MISO regions that benefit from these projects. Projects that MISO considers to be Baseline Reliability Projects (BRPs), Market Efficiency Projects (MEPs) or Multi-Value Projects, for example, are eligible for such cost-sharing. 

However, a significant amount of transmission development in MISO’s territory are local projects to address aging infrastructure and are not subject to cost-sharing or other MISO processes that can ease the cost and time of their development. The problem is that there is no consolidated process for determining whether these localized projects should meet the criteria to elevate them to the status of a BRP or MEP. Transmission Owners are not required to engage with stakeholders in a transparent manner to evaluate local “age & condition” transmission plans for meeting local transmission needs.  As a result, customer perspectives and concerns about rate impacts may not be as focused from this process and altogether excluded from local transmission planning.  

The result is that opportunities to make potentially hundreds of transmission projects more cost-effective, thus easing the costs of not only transmission development but the entire clean energy transition, are being lost. [1]  

Another example is that PAC2020-1, as defined by the Coordinated Planning Process Task Team that MISO kicked off in November 2019, called for a process to identify transmission issues and needs that are common to generator interconnection, reliability planning, and economic planning processes and to help identify projects that can fulfill objectives within one or more of those three subject areas. PAC2020-1 also calls for a process to ensure transmission upgrades receive the correct designation (such as BRP) under MISO tariffs. It also calls for MISO to evaluate how the timing of these various processes can be better aligned so that designations are applied in time for a needed upgrade to benefit from that designation. These processes that would occur under PAC2020-1 can provide a venue for stakeholders to request the information needed to make the case for a given designation. 

By closing these issues, MISO could cause progress toward the development of these important processes to essentially end. Therefore, the Public Consumer Advocate Sector hereby goes on record to support keeping these matters on its list of future issues even if MISO determines to classify these as inactive. 

 Respectfully submitted,

John Wachtler

Planning Advisory Committee Representative

Public Consumer Advocate Sector

The Competitive Transmission Developer (CTD) sector submits these comments in support of the Environmental Sector’s request to hold open two issues that have been tracked on the MISO Integrated Roadmap. As an initial matter, we note that it’s unclear how these issues could be closed without addressing the drivers that caused the issues to be raised. MISO staff has offered the view that stakeholders need to “own” issues; however, resolving issues also requires time and commitment from MISO staff.

The CTD sector believes that keeping the following two issues open – in an inactive status, if MISO does not currently have sufficient staff to address them – is in the interest of the MISO stakeholder community for the reasons discussed below.
• Coordinated Planning (PAC2020-1)
• Consolidated Planning (PAC2020-4)

Coordinated Planning (PAC2020-1) would involve considering adjustments to MISO’s regional planning process to ensure that planning for reliability and economic needs, as well as generator interconnections and generator retirements, is coordinated. This could include identifying system needs that are common across these planning “sub-processes,” and project solutions that could address multiple system needs. Process changes like these could result in the identification of projects that are more cost-effective and provide multiple streams of benefits for customers.

Consolidated Planning (PAC2020-4) would evaluate the transmission needs that are currently driving smaller local projects in MTEP Appendices A and B, as well as Network Upgrades driven by generator interconnections, and consider more comprehensive regional solutions to more cost-effectively meet these needs. The CTD sector observes that MISO’s tariff already requires consideration of regionally planned alternatives that may be more efficient or cost-effective than Transmission Owner-proposed projects. This issue simply proposes that MISO also consider alternatives to generator interconnection-related upgrades – as well as codifying specifically how regional alternatives are evaluated for all of these project types. The CTD sector would appreciate a better understanding of this.

Adopting the planning enhancements proposed in issues PAC2020-1 and PAC2020-4 would likely result in greater transparency, improved coordination across MISO’s planning sub-processes, and selection of more cost-effective projects in the regional transmission plan. As such, the CTD sector supports keeping these issues open until the associated process improvements can be fully considered by MISO staff and stakeholders.

Mississippi Public Service Commission (MPSC) Feedback Regarding

Inactive Issue Proposal – PAC (20230308)

MISO Requested Feedback Statement:

In the March 8th meeting of the Planning Advisory Committee (PAC), MISO proposed closing two parking lot/inactive issues: PAC-2020-1 Coordinated Planning and PAC-2020-4 Consolidated Transmission Planning.  On April 26th, the Environmental Sector offered a response presentation to the PAC arguing for keeping both issues open.  MISO is interested in input from sectors on whether these issues should remain on the issues list when measured against other work on the Reliability Imperative (e.g., LRTP).  Any comments on the governance protocol and procedures for closing an issue should be directed to the Stakeholder Governance Working Group (SGWG) when they take it up this summer.

The comment period was extended to May 12th.

Feedback:

The MPSC supports closing these two parking lot/inactive issues: PAC-2020-1 Coordinated Planning and PAC-2020-4 Consolidated Transmission Planning.

The Environmental/Generation Developer (ENV-GD) group premises the extension based on planning efficiency. However, it is clear that the importance of these initiatives to the ENV-GD groups is in the conversion of the transmission upgrades required by new generator interconnections into Baseline Reliability Projects (BRPs), Market Efficiency Projects (MEPs) or “Other” projects, which would shift those interconnection costs from generation developers to MISO load, as generation developers pay no share of BRP, MEP, or “Other Project” costs. 

New generators that interconnect to the MISO grid without an obligation to serve load must understand their cost of interconnection is part of the cost of doing business.  If they enter into a power sales agreement with an LSE to serve load, they have the ability and incentive to include and recover those costs through the negotiated rates under the agreement.

MISO already considers avoidance of BRPs costs as a benefit in the economic analysis of MEPs. “Other” projects, typically related to new load service and economic development goals of the TO and their regulator, cannot easily be replaced by alternatives proposed by the RTO or others, as these often conflict with the state regulatory sanctioned utility transmission expansion plans. 

Finally, MISO load is already on track to pay tens of billion for Long-Range Transmission Planning (LRTP) MVPs.  These LRTP projects are intended to facilitate the transmission of energy from the GDs’ renewable generation and other generation to MISO load.  These projects will reduce the costs to GDs for interconnection-related network upgrades, while also allowing the independent generator owners to pay nothing for the existing MVPs.  Therefore, shifting the remainder of the generator interconnection costs to load under the guise of BRPs, MEPs, and “Other” projects, is neither just nor reasonable.

For all the above reasons, this Commission supports MISO’s proposal to retire both parking lot/inactive issues: PAC-2020-1 Coordinated Planning and PAC-2020-4 Consolidated Transmission Planning.

The Citizens Utility Board of Michigan appreciates the opportunity to provide stakeholder feedback regarding the closing of two inactive PAC issues proposed for closure: Coordinated Planning Process PAC-2020-1 and Consolidated Planning Process PAC-2020-4. We wholeheartedly support the environmental sector’s concerns about the premature closing of these issues.  We also are concerned about a lack of a formal process of closing issues without adequate stakeholder input.  

Regarding the two PAC issues, we acknowledge that the LRTP process has adequately addressed some of the initial concerns that brought these issues to the forefront in 2020.  However, we believe more can be done to achieve the most cost-effective transmission expansion possible.  As a nonprofit organization, we are dedicated to look out for residential ratepayers.  With transmission costs growing as a percentage of customer bills, according to the U.S. Energy Information Administration, a trend likely to grow given the large amount of transmission development necessary to enable clean energy project development so the country can meet emissions reduction goals. 

The root of the problem with regards to consolidated planning seems to be a lack of coordination between large transmission projects that may cover several states and local projects within a state.  A significant amount of transmission development in MISO’s territory are local projects to address aging infrastructure and are not subject to cost-sharing or other MISO processes that can ease the cost and time of their development. Transmission owners are not required to engage with stakeholders in a transparent manner to evaluate local “age & condition” transmission plans and as a result, residential ratepayer interests can be excluded from local transmission planning and stuck with the costs. For example, would it be cost effective to expand a local 4-lane highway when a new Interstate highway is planned only a few miles away?  The problem is aggravated by the fact the 4-lane highway expansion is paid by local or state funding when the new Interstate costs are spread among several states. 

We are also concerned that many developers with renewable projects coming through the generation interconnection (GI) queue do not proceed with their developments because the existing transmission grid could not accommodate their projects without the developers paying millions of dollars. We acknowledge that cost allocation issues are being addressed in the LRTP and JTIQ planning processes.  However, we believe more can be done to achieve a more coordinated process. 

For these reasons, we support the environmental sector’s objection to closing these two important issues.

General Counsel

Citizens Utility Board of Michigan

Alternate Member – Planning Advisory Committee

Public Consumer Advocate Sector

The Environmental Sector appreciates this opportunity to provide additional comments on the issue of whether PAC 2020-1 (Coordinated Planning) and PAC 2020-4 (Consolidated Planning) should remain on MISO’s Roadmap in inactive status. Our sector submitted substantive comments on why these two issues should remain on the Roadmap, including a history of these two issues and details of how they have not been fully addressed to date, posted via the Feedback tool on April 21, 2023.

We submit these additional comments to address the process issues related to closing any Roadmap issue, that also apply to these issues.  We recognize that MISO staff availability is limited given a variety of other efforts currently underway.  But staffing limitations do not justify closing an issue without a clear process for closing issues, especially when such a process is expected to be developed soon through the Stakeholder Governance Working Group (SGWG). Nor do staffing limitations justify closing an unresolved issue that can simply remain in inactive status.

MISO has pointed to an August Steering Committee (SC) presentation for the details of how it planned to address issues in the Roadmap Parking Lot.  That presentation states that stakeholders must present justification for any issues that a stakeholder requests to stay open, or move to active, and that formal feedback may be requested for support of this request.  The Environmental Sector made such a presentation at the April 26, 2023 PAC meeting, and feedback has been requested through the Feedback Tool.  But this SC presentation does not detail the process that should follow these presentation and feedback steps. In particular, MISO has said that any Roadmap issue that MISO has recommended be closed requires stakeholder ownership to remain on the Roadmap.  Yet there is no clarification about what stakeholder ownership of an issue entails.  Given the lack of clarity on the process for closing an issue, and the fact that retaining an issue inactive status requires no staff time, we again urge MISO and stakeholders not to close PAC 2020-1 and 2020-4.  At the very least, no action should be taken until the SGWG has clarified the process for closing a Roadmap issue.

Respectfully submitted on behalf of the Environmental Sector, 

Natalie McIntire

Coordinated Planning (PAC 2020-1) and Consolidated Planning (PAC 2020-4) Should Remain on MISO’s Roadmap  

The Environmental Sector requests that MISO maintain both issues PAC2020-1 and PAC2020-4 on MISO’s Roadmap because neither has been fully addressed, and both should be retained until resolved.  The Environmental Sector recognizes and appreciates that MISO is resource limited.  Therefore, we ask that MISO make these two issues inactive and we will revisit them after MISO obtains additional resources or has advanced further in its LRTP process.   

At its heart, Coordinated Planning (CPPTT) is focused on generation interconnection and ensuring comparable treatment, and Consolidated Planning is focused on ensuring the efficiency and effectiveness of the bottom-up baseline reliability process. 

• PAC2020-1: We remain concerned that there is still the possibility for generator interconnection upgrades or transmission service request upgrades to meet the criteria of other project types per the project hierarchy in the tariff, yet there is no process to conduct this evaluation.  We also recommend that MISO periodically review the study objectives, methodologies, modeling assumptions and timelines used in MISO's planning processes as described below to ensure comparable treatment.

• PAC2020-4: MISO still does not (a) have a robust process for considering more cost-effective alternatives that could replace two or more smaller projects such as those identified by Transmission Owners (TOs) in their bottoms up process and upgrades identified in the interconnection process or (b) require TO’s to submit asset replacement plans early enough to consider alternatives.   

(A complete discussion and history of these two issues are provided in the Appendix.)

JUSTIFICATION FOR RETAINING THE CPPTT AND CONSOLIDATED PLANNING ROADMAP ISSUES - EVEN IF THEY ARE INACTIVE: 

First, MISO did not address some of the issues of both CPPTT and Consolidated Planning.  

Second, MISO indicated that some of the unresolved issues of CPPTT and Consolidated Planning could be resolved by the LRTP process.  To date there has not been a discussion about how, if at all, the LRTP process has resolved those issues.  Indeed, the LRTP planning process is not yet complete so it is unclear whether that discussion should happen now or at the completion of LRTP.  A full stakeholder discussion of how LRTP addresses the multiple aspects of both Roadmap issues should be conducted before either of these issues is closed.

Third, the concerns that gave rise to the CPPTT still remain. While MISO’s LRTP process is intended to identify larger regional lines needed to ensure reliability as new generation is added to the system, MISO still has not clarified a process that can evaluate whether a transmission project required for either generator interconnection or a transmission service request also meets the criteria of a BRP or MEP as required by the project hierarchy under Attachment FF Section III.A.2.j.  If LRTP is completed on a regular basis, it may address large regionally beneficial lines as opposed to such lines being required in the interconnection process.  However, we do not have confidence of that future because of the following:  

• LRTP studies are taking multiple years to complete, 

• the regularity of LRTP cycles has not been established, and

• interconnection requests submitted during the in-between years could again drive upgrades that bring much broader benefits. 

This aspect of the tariff deserves more consideration and a process by which projects can be evaluated to see if they meet the criteria of other project types. 

Fourth, the concerns that gave rise to the Consolidated Planning Roadmap Issue remain. There is little evidence that MISO conducts its own robust review of alternatives in baseline reliability planning but instead, primarily relies on its TOs to submit alternatives.  (For MTEP23, transmission owners submitted what are akin to backbone 500 kV projects as baseline reliability projects costing several billion dollars.  It is unclear how MISO will be evaluating alternatives to these backbone projects through the bottom-up process.)  Under Order 1000, FERC Ordered “Through the regional transmission planning process, public utility transmission providers will be required to evaluate, in consultation with stakeholders, alternative transmission solutions that might meet the needs of the transmission planning region more efficiently or cost-effectively than solutions identified by individual public utility transmission providers in their local transmission planning process.”  Order 1000 ¶ 148. 

Fifth, TOs do not submit their age and condition replacement projects in time for MISO to consider anything other than a like-for-like replacement.  

Again, we ask that MISO make these two issues inactive so that stakeholders can revisit them after MISO obtains additional resources or has advanced its LRTP process.  

Appendix: History of Two Roadmap Issues 

Coordinated Planning (PAC2020-1) (a/k/a “CPPTT”): MISO’s description of this Integrated Roadmap is as follows: 

Evaluate and consider potential adjustments to MISO's planning process to ensure comparable treatment: reliability planning, economic planning, transmission service request, generator interconnection and generator retirement.  Investigation includes areas of A) study objectives, methodologies, and assumptions; B) coordination and information exchange; and C) timing alignment.

In November 2019, the Coordinated Planning Process Task Team (CPPTT) held a kickoff meeting to write its mission statement and scope.

The CPPTT identified five issues to be addressed by the PSC or the PAC:  

A. 1.  Review current study objectives, methodologies, modeling assumptions and timelines used in MISO's planning processes - reliability planning, economic planning, transmission service request, generator interconnection and generator retirement. Identify and document rationale for any disparities between them. [Discussion kicked off at April PSC]

A.2     Once the study objectives, methodologies and modeling assumptions described in A.1 above are reviewed, evaluate what potential adjustments are required to the methodologies and/or modeling assumptions for the reliability planning, economic planning, transmission service request, generator interconnection and generator retirement processes to ensure comparable treatment.

B.1     Develop a process that enables adequate coordination and information exchange required to identify transmission issues/needs that are common to generator interconnection, reliability planning, and economic planning processes; and that provides an opportunity to identify cost effective solutions that may meet multiple needs as per the requirements in Attachment FF Section I.D of the MISO Tariff.  [MISO stated “Item # 2 under Integrated Roadmap Issue IR090 (Implement consolidated transmission planning) is similar to Issue B.1 identified by CPPTT and can be addressed through a single effort”.]

B.2  Develop or clarify a process that permits correct evaluation and designation of a transmission project/upgrade as per the MISO Tariff (GIP, BRP, or MEP) as required under Attachment FF Section III.A.2.j of the MISO Tariff.

C. Timing Alignment:  Evaluate how timing of reliability planning, economic planning and generator interconnection processes could be better aligned to ensure adequate coordination between the respective processes for correct designation for a transmission project/upgrade as per the MISO Tariff.  [MISO stated “Issues B.1 and C identified by CPPTT can be combined and addressed through a single effort”.]

Consolidated Planning (PAC2020-4):   

This Integrated Roadmap issues was submitted in 2020 on behalf of both the Environmental and IPP Sectors.  The description of the Issue is as follows:

Develop a process by which MISO consolidates, to the maximum extent possible, the transmission needs identified as the basis for smaller projects in Appendices A and B as well as the needs driving the advanced projects in the interconnection queue to develop larger, more comprehensive projects that would meet the needs for the smaller projects in a more cost effective way. Additionally, if the TO’s also provided lists of other transmission assets that were nearing the end of their useful lives and in-need of a rebuild say within 10 or 20 years, MISO could incorporate those needs within the same process. In short, MISO should be planning for the consolidated needs of the projects specified under the bottom up approach as is required under Attachment FF. The result could be a system that more efficiently meets the various needs on the system and is also more capable of timely accepting proposed interconnections and thereby providing more energy choices for utilities and consumers.

Stakeholders overwhelmingly voted this issue as the most important issue of all PAC issues voted on and MISO declared Consolidated Planning a "High Priority" in 2020.

Coordinated Planning (CPPTT) and Consolidated Planning are Distinct Issues: 

The two issues address different topics, and thus should not be combined into one.  While MISO has consistently tried to merge CPPTT and Consolidated Planning, they are distinct.  At its heart, Coordinated Planning (CPPTT) is focused on generation interconnection and ensuring comparable treatment, and Consolidated Planning is focused on ensuring the efficiency and effectiveness of the bottom-up baseline reliability process.  Four of the five CPPTT issues were unrelated to Coordinated Planning; only CPPTT B.1. is pertinent to Consolidated Planning. 

The original submission on Consolidated Planning focused on two issues in the bottoms-up process: 

1. Ensuring that MISO was considering alternatives and identifying the most efficient solutions to reliability needs in the “bottom up” process, and 

2. Requiring submission of aging asset data to enable MISO’s consideration of alternatives to like-for-like replacements. 

These original issues of Consolidated Planning are not a part of CPPTT and were never considered by MISO.  

The Consolidated Planning issue then evolved to include another issue: eliminating the planning silos among baseline reliability, market efficiency and generation interconnection planning, i.e. MISO designing a more holistic planning process.  It is this third issue, holistic planning, that is similar to CPPT B.1.  However, holistic planning was never considered at MISO through the CPPTT or in Consolidated Planning. 

MISO’s Consideration of CPPTT  and Consolidated Planning:  

CPPTT:  

MISO has not “resolved” all five CPPTT issues but addressed them as follows:  

• Issues A.1. and A.2 - on 12/1/21 “MISO presented conclusions for the discussions on study objectives, methodologies and assumptions during the PSC.  MISO concludes that the approaches currently used are appropriate.  Different approaches will continue to be explored.”

• Issue B1 - this issue was never discussed or addressed at MISO. 

• Issue B2 - Project Hierarchy - on 2/10/21 MISO concluded that “the discussion on project hierarchy should wait until more information is known from the LRPT effort.”  A discussion in the PAC was supposed to occur in Q4 2021, but that did not occur.  The Stakeholders agreed to table this discussion temporarily to allow MISO to focus on LRTP planning.  

• Issue C - Alignment of interconnection study process with other MTEP planning processes to facilitate evaluation under Issue B.2.  The interconnection study process has been adjusted and can be completed in about a year at this point. This should allow for better alignment with other MTEP processes, however, no work has been done to complete B.1 or B.2, or to consider how the multiple planning processes can be aligned to better inform each other so that the most optimal solutions can be identified.

For full history of CPPTT see https://www.misoenergy.org/stakeholder-engagement/MISO-Dashboard/coordinated-planning-process/

The Environmental Sector recommends that MISO complete CPPTT issues B.1, B.2, and C and revisit Issues A.1. and A.2 on a regular schedule, perhaps every 5 years.

CONSOLIDATED PLANNING: 

MISO never really took any meaningful steps to consider Consolidated Planning but instead quickly concluded that the LRTP process could address these issues.  For a full history of Consolidated Planning see https://www.misoenergy.org/stakeholder-engagement/MISO-Dashboard/consolidated-transmission-planning/.

While LRTP does a good job of considering multiple drivers for new transmission, and in that way can do a better job of identifying cost-effective solutions that meet multiple needs, the LRTP process is focused on regional transmission planning.  It cannot address the kind of consideration this issue was initially intended to address - looking for alternate transmission solutions that can meet multiple needs (bottoms up reliability, age and condition replacements, generator interconnection upgrades, etc.) in a more cost-effective way.

On March 8, 2023, MISO proposed to close both the Coordinate Planning Process PAC - 2020-1 and the Consolidated Planning Process PAC-2020-4.  MISO justified its recommendation at the PAC as follows: 

• “Work complete as requested and remaining items do not align with MISO Roadmap”

• “LRTP and JTIQ work addresses many of the initial concerns from these two issues and remains the priority”

The MISO website says closure is due to “due to lack of current relevance or resources.”  We do not agree that work on these issues is complete nor that they lack relevance today or in the future.