PAC: JTIQ Updated Approach (20231115)

The TDU Sector supports the approach MISO is adopting in continuing discussions with SPP regarding JTIQ projects, as described at slide 7 of MISO’s presentation (https://cdn.misoenergy.org/20231115%20PAC%20Item%2008b%20JTIQ%20Status%20Update630871.pdf).

The Environmental Sector appreciates MISO and SPP’s continued work to develop JTIQ, a repeatable seams interconnection study process that can provide more timing and cost certainty for interconnection customers and identify more cost-effective transmission solutions to support new generation interconnections across multiple cluster study cycles.  We encourage MISO and SPP to work with stakeholders to finalize and file the JTIQ tariff language as soon as possible.  The five transmission solutions in the first JTIQ portfolio have the potential to support needed new generation capacity in MISO and SPP and bring a range of other benefits to consumers in these regions.

Regarding the recent updates to the JTIQ proposal presented at the November PAC meeting, our sector generally supports this direction for the first JTIQ portfolio.  Given the recent announcement of the significant funding award from DOE for this first JTIQ portfolio, and the challenges MISO and SPP have faced addressing the complicated rate design issues and the differences between the two regions relative to allocating costs for generator interconnection network upgrades to load, the proposed updates on slide 7 appear to be a reasonable path forward to finalize the JTIQ process.

While MISO’s tariff normally assigns 10% of costs for 345-kV interconnection projects to load, MISO noted that the DOE funding would pay for load’s 10% share and therefore, MISO is proposing that generators pay for all of the JTIQ costs remaining after the DOE funding is applied. We appreciate that MISO indicated that assigning to generators 100% of remaining JTIQ costs is intended to apply to this first JTIQ portfolio only, and that cost allocation will be revisited for any future JTIQ portfolios.  It will be important to clarify this point in the transmittal letter to FERC and in MISO and SPP’s proposed tariff revisions - that the 100% cost allocation to generators is for this first JTIQ group alone and that MISO and SPP will revisit JTIQ cost allocation in the future.

The NDPSC does not support allocating 100% of the JTIQ projects’ O&M cost to the constructing TO zone as is currently proposed. We believe these costs should be shared more broadly to reflect the regional benefits these projects provide. Under the previous MISO proposal, 10% of the O&M costs associated with the JTIQ projects were to be allocated to MISO load.  MISO put this in place because that aligned with 10% of the JTIQ project costs that were to be allocated to MISO load.  However, even though the current proposal allocates no construction costs to load (because of the DOE funds), the 345 kV projects provide undeniable regional benefits, and therefore, sharing 10% of the O&M still makes sense. Under the current tariff, a 345 kV Generator Interconnection Network Upgrade would have 10% of the O&M costs collected from regional load, so this treatment would be consistent with current O&M practice for this project type.

Mississippi and Louisiana Public Service Commissions’ Feedback Response to JTIQ Update and Next Steps

In the November 15, 2023 meeting of the Planning Advisory Committee (PAC), MISO opened a feedback request for the suggested changes to the JTIQ proposal summarized on slides 6 and 7. Comments are due by December 6.

Feedback: 

The Commissions offer the following feedback on slides 6 and 7:

1. Slide 6 needs clarification. In the Recent Updates text box, MISO states that 100% of the JTIQ portfolio costs will be allocated to Interconnection Customers. But the flow chart shows the “DOE Funding to be applied to 10% Load first.”

a. Is the flowchart incorrect? The text states that load no longer pays 10%. Please describe whether 10% is being allocated to load, but is being erased by the DOE funding, or whether zero percent is being allocated to load? How would this be applied to future JTIQ projects without DOE funding?

b. What is included in the portfolio E&C costs? Are there costs beyond E&C costs that are being allocated to Interconnection Customers, or only portfolio E&C costs?

2. Slide 6 says: “All O&M will be borne by the constructing zone” And the following bullet point references "each region".

a. Does "constructing zone" as applied to MISO mean Transmission Pricing Zone or something else?
b. Does "each region" reference the entire MISO footprint or something else?
c. Will MISO South be allocated any O&M costs associated with the currently planned JTIQ projects?

3. Slide 6 says: The RTO has discretion to determine cost allocation for O&M to achieve “uniformity.” Uniformity with what? Does uniformity apply as between RTOs, within the MISO footprint or within MISO Subregions (e.g., MISO North, Central or South)?

4. Slide 6 flowchart says “100% Entitlements to Construction Zone RTO.” What does MISO mean by the term “Entitlements”?

5. Slide 6 text box says “Backstop will be constructing region load.”  FN1

The Commission continues to object to using load as the backstop (surety) of JTIQ construction costs.

The purpose for JTIQ is to reduce costs to Interconnection Customers (e.g., generators) by coordinating transmission expansion to reduce/eliminate redundant transmission expansion. In other words, JTIQ benefits Interconnection Customers.

The purpose of JTIQ is NOT to shift transmission upgrade costs from Interconnection Customers to Load. If insufficient Interconnection Customers sign-up to cover the full JTIQ costs (after DOE funding is applied to reduce those costs), then Interconnections Customers, not load, should provide backstop funding, until such time that the JTIQ facilities are fully subscribed. Interconnection Customers are both the cost causers and the beneficiaries of the JTIQ projects.

6. Slide 7 requires clarifications:
a. Includes the same contradiction: that Interconnection Customers pay all JTIQ costs and that Load pays 10%. States DOE funds to pay Load’s 10%.
b. Same questions regarding cost recovery in constructing region.
c. Same questions regarding O&M cost recovery. How can SPP and MISO use the same rate design but allow for variation in each RTO?
d. Same questions and concerns regarding backstop funding (i.e., Load as surety)?
e. Same question regarding entitlements. What does MISO mean?

7. Please advise stakeholders promptly as to when proposed JOA and Tariff language changes will be available to stakeholders for review and comment. Recognizing that MISO plans to file these changes with FERC in early March 2024, the draft JOA/Tariff language should be available in early January 2024.

[FN 1] The LPSC does not join in Comment No. 5.

End Use Sector Feedback Regarding MISO’s JTIQ Cost Allocation Approach[1]

At the November 15th meeting of the Planning Advisory Committee (PAC), MISO presented its latest proposal regarding cost allocation associated with Joint Targeted Interconnection Queue (JTIQ) related upgrades along the SPP-MISO seam. While MISO intends to further vet the cost allocation proposal in 2024, initial stakeholder feedback regarding MISO's cost allocation proposal was requested at the November PAC meeting.   The End Use Sector appreciates the opportunity to respond to MISO’s request for feedback.

MISO indicated that JTIQ has been selected as a recipient of DOE’s Grid Resilience and Innovation Partnership (GRIP) program. In total, this funding is expected to offset $464.5 million of JTIQ cost. [2]  MISO & SPP’s latest estimate indicates that the overall cost of the JTIQ portfolio is expected to be between $1.21& $1.67 billion.  MISO indicated that the two regional transmission organizations have determined that in light of DOE’s GRIP grant and concerns with equitable treatment of JTIQ project costs and risk between MISO and SPP stakeholders, MISO & SPP are making near term adjustments to ensure success of the portfolio.[3] As a first step, MISO and SPP propose to offset the total investment costs by the DOE awarded GRIP related funds.  Doing so will more than offset the 10% of the engineering and construction costs that was initially proposed to be allocated to load, thereby resulting in the remaining amount of the costs to be recovered entirely from generation interconnection customers.  The on-going operations and maintenance (O&M) costs continue to be proposed to be allocated to the transmission owning entity (and therefore, load) within the relevant construction zone.

The End Use Sector supports MISO’s proposed approach to allocate 100% of the net costs (i.e., after deducting the GRIP funds) to the generation interconnection customers. Since the JTIQ initiative consists of upgrades to accommodate a potential range of 28 GW to 53 GW in new generator interconnection projects near the seam, the 100% cost assignment would properly follow cost causation principles by allocating costs to the cost causers. That is, such an approach appropriately reflects that the projects are planned to serve generator interconnections.  Furthermore, MISO has explained that the DOE GRIP grant and concerns about differential cost allocation approaches between SPP and MISO “requires MISO & SPP to make near term decisions for the success of the portfolio.”[4]  Accordingly, MISO should align its cost allocation approach with SPP’s approach to avoid jeopardizing the GRIP grant opportunity (and thus the JTIQ). 

While the 100% allocation of the engineering and construction costs to the generating interconnection customers is a step in the right direction, the End Use Sector is concerned about the following and recommends to MISO to address these concerns in forthcoming stakeholder discussions in 2024:

1. At present, the proposed approach is to allocate 100% cost assignment of the O&M costs to the construction Transmission Owner (TO) zone, which means that the load in the specific zone would bear these costs.  Assigning 100% of the O&M costs to loads is inconsistent with the proposal to allocate 100% of JTIQ construction costs to interconnecting generators.  Moreover, if the O&M costs are allocated to loads as MISO proposes, the allocation of these costs within the MISO footprint should be commensurate with the distribution of JTIQ project benefits.  Given the magnitude of the project costs involved, it is important that MISO conduct an analysis to show the projected O&M cost impacts and the distribution of JTIQ project benefits by TO construction zone as an initial step.  MISO also needs to demonstrate how the 100% assignment of O&M costs to loads within the constructing TO zone is fair and follows the cost causation and beneficiaries pay principles.
2. The End Use Sector is concerned about the risk that load continues to undertake by being the de facto project guarantor. Under the current MISO generator interconnection process, network upgrades are constructed after the agreements are in place by interconnecting customers committing to paying for the cost. However, under the JTIQ approach, the project would be constructed by the relevant TO.  While the generation interconnection customers would be technically responsible for 100% of these construction costs if they all subscribe, load would bear the initial cost and the risk if insufficient generators ultimately subscribe to the program.  While the DOE GRIP funding will assist in reducing the risk exposure by lowering the initial investment, this issue needs to be vetted further to ascertain what controls can be put in place to mitigate the risk to load of generator interconnections not materializing as expected.  Loads should not be required to serve as a backstop for JTIQ investments without appropriate guardrails to limit the exposure of loads to the risk that the JTIQ portfolio is not fully subscribed. 

The End Use Sector appreciates the opportunity to comment. If you have

any questions regarding these comments, please do not hesitate to contact any of the following representatives:

Kavita Maini

End Use Sector PAC Representative

KM Energy Consulting, LLC (Consultants to MIC)

(262) 646-3981

kmaini@wi.rr.com

Ken Stark

McNees Wallace & Nurick LLC (for CMTC)

(717) 237-5378

kstark@mcneeslaw.com

Jim Dauphinais

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(636) 898-6725

jdauphinais@consultbai.com

Ali Al-Jabir

Brubaker & Associates, Inc.

(Consultants to ABATE, IIEC, LEUG, NLCG and TIEC)

(361) 994-1767

aaljabir@consultbai.com

The MISO Transmission Owners submit the following feedback in response to the Updated JTIQ Approach presented at the November 15, 2023, Planning Advisory Committee meeting.  The Updated JTIQ Approach proposal would allocate 100 percent of the transmission operations and maintenance (O&M) costs related to the JTIQ project costs to the constructing region with each region deciding how to treat the recovery of the costs.  MISO is proposing to recover 100 percent of O&M costs from the load in the zone of the constructing transmission owner.

The MISO Transmission Owners do not support allocating JTIQ-related O&M costs only to the load in the zone of the constructing transmission owner.  The allocation of O&M costs to only the load in the constructing transmission owner zone is not appropriate because the JTIQ projects are significantly larger in scope, scale, and purpose than conventional MISO-only generator interconnection projects. The JTIQ projects address the Affected Systems issues at the seam and as proposed, the costs fall disproportionately on the loads in the transmission owner zones on the MISO and SPP seam. For the reasons stated above, the MISO Transmission Owners support sharing these O&M costs throughout MISO, instead of burdening only the load in the zone of the constructing transmission owner.

The OMS Transmission Cost Allocation Work Group (TCAWG) and Seams Work Groups (SWG) provide this feedback to MISO on its updated cost allocation methodology for the Joint Targeted Interconnection Queue (JTIQ) project portfolio. This feedback is from an OMS work group and does not represent a position of the OMS Board of Directors. 

On October 18, 2023, the Department of Energy (DOE) announced that the JTIQ portfolio was selected as a recipient of DOE’s Grid Resilience and Innovation Partnership (GRIP) program. In total, this funding will help offset $464.5 million of the JTIQ cost (estimated $1,210 – $1,670 billion).

At the November 15 meeting of the Planning Advisory Committee, MISO announced that the GRIP funding would be used to eliminate the 10% of project costs assigned to load and that the remaining GRIP funds would be assigned to interconnecting customers.

The TCAWG and SWG support MISO and SPP’s proposed use of the GRIP funding and believe it is the most equitable and streamlined allocation. Furthermore, this adjustment in the allocation method will follow SPP’s existing cost allocation methodology for Generator Interconnection Projects thereby avoiding a FERC filing and ruling. 

Savion appreciates the opportunity to provide these concerns in regard to the JTIQ.

1. The SPP/MISO proposal allows for only a one-time opportunity for GI customers to use the JTIQ security they post to advance beyond Decision Point 1 of the MISO DPP and the SPP DISIS. If the IC withdraws, their JTIQ security is lost with no opportunity for refund and no ability to use those funds for subsequent GI requests submitted in later study clusters. We propose SPP/MISO allow GI customers, that must withdraw after posting JTIQ security, the right to use the same security for subsequent GI requests submitted in later study clusters.   Allowing for this flexibility harms no one (since the funds go towards actual JTIQ costs) but will give ICs more comfort in posting the security initially and allows them more flexibility to make use of the JTIQ security at a later time. This would negate much of the punitive nature in the current JTIQ security design.

2.  SPP/MISO hasn't yet provided sufficient insight as to whether ICs will be granted ARRs for the JTIQ NUs they have funded. 

3. MISO/SPP have failed to address what will happen in the event a GI customer on another transmission system (e.g., AECI, MPC) has an affected system impact on the JTIQ portfolio. Do those GI customers become financially responsible for funding JTIQ upgrades? With those external GI customers be studied with the same criteria as customers in SPP and MISO?

4. MISO is currently pursuing queue reform changes that require $8k/MW to enter Phase 1 and another $1k/MW minimum at DP1. When this is combined with a JTIQ M1 at DP1, which is expected to be $3k/MW or higher, the at-risk dollars to advance beyond DP1 will be $12k/MW or higher with at least $7k/MW nonrefundable. This is excessively high nonrefundable funds when the GI customer hasn’t yet received an affected system study result. This is unacceptable.

5. MISO/SPP have not sufficiently addressed how the addition of JTIQ NU cost obligations will impact the penalty free withdrawal provisions described in their respective LGIPs. MISO/SPP need to explain the cost basis that will be used when determining penalty free withdrawal in light of JTIQ NU costs. Will security for JTIQ NU be refundable if a GI customer's cost exceeds the PFW threshold?

6. The JTIQ construct allows SPP/MISO to peer into the neighboring system up to 5 busses for purposes of identifying additional affected system upgrades in addition to the JTIQ upgrades. This is unjust. If SPP’s model can be used to identify upgrades on MISO, and MISO’s model can be used to identify upgrades in SPP, then why can’t SPP and MISO form a single model that is used across both footprints to form a single GI queue that spans both footprints? This would eliminate the need for affected system studies between SPP and MISO and would possibly eliminate the need for JTIQ NUs.  Even if this isn't acceptable, the cost containment justifications given in early discussions of JTIQ are undermined when additional affected system upgrades are identified as SPP/MISO is presently proposing.

7. The 5% OTDF/PTDF and 1 MW impact criteria for identifying GI customers that will be responsible for posting JTIQ security is an exceedingly harsh criterion and does not align with Order 2023 criteria for studying affected system impacts. It is also our opinion that the 5% OTDF/PTDF criteria should be changed to match the Order 2023 affected system study criteria.

8. The DOE granted $464M towards JTIQ. If MISO+SPP’s combined cost responsibility is 10% of $1.67B, which is $167M, what will MISO/SPP do with the excess $278M?  Since SPP and the state of Minnesota used the entire cost of the JTIQ portfolio to acquire the federal funds (in fact they used an inflated number), the excess funds should be used to offset GI customers' JTIQ obligation and should not be diverted to fund other projects not included in the JTIQ portfolio. 

8. Savion staff has substantial concern regarding how MISO/SPP will determine MW-impact for identifying JTIQ cost responsibility. As we understand it, the following formula's would be used to determine JTIQ cost responsibility:

• Dfax criteria (OTDF 5%) AND
• MW change on JTIQ NU Line >1MW between benchmark and study case

We believe this design will unjustly impact projects located very far from the JTIQ NUs, while nearby projects with a larger impact have the same security requirements. We propose the following additional criteria be added to the determination: 

• MW Impact Criteria (if Project MW Impact (Dfax * Project MW) meets a certain threshold, say X% of JTIQ NU Line Rating)
  

Clean Grid Alliance and Advanced Power Alliance Comments to the PAC on JTIQ Updated Approach

December 6, 2023

At the November 15, 2023, meeting of the Planning Advisory Committee (PAC), MISO presented an updated approach to several elements of the Joint Targeted Interconnection Queue (JTIQ) project portfolio.  Those changes are outlined on slide 7 of the posted presentation and include E&C Cost Allocation Methodology, Operations & Maintenance, Backstop, and Entitlements under Appendix G of Congestion Management Process.  

Clean Grid Alliance (CGA) and Advanced Power Alliance (APA) appreciate the opportunity to provide input on the JTIQ updated approach and offers the following  comments to the changes in the last proposal. Comments submitted previously should be considered as continuing to be maintained as though fully set forth herein: 

• Cost Allocation: CGA and APA, along with other MISO and SPP stakeholders, oppose a 100% cost allocation to generators. The unilateral decision to move from the 90/10 proposal to placing 100% of the costs on generators does not align with the benefits that will accrue to load with these projects. What makes this change to the proposal more objectionable, is its applicability to potential future JTIQ proposals. First there is not likely to be any DOE funding in any future rounds to offset the costs of similar projects in future rounds. Second, the use of a stationary cost allocation method in this case is inappropriate and may constrain MISO and SPP from developing seams related projects in the future and may prevent them from looking at a multivalued set of projects that have broad benefits beyond those that may be targeted just for the interconnection of generations. With the absence of DOE funding, even a 90/10 generator to load cost allocation methodology is untenable. Tariff language that reflects an annual analysis of the benefits to inform cost allocation discussions is what stakeholders and MISO had discussed in previous JTIQ meetings. MISO has affirmed in past JTIQ meetings that the 90/10 cost allocation without DOE funding will not be proposed to be set in the tariffs for future years, and certainly a 100/0 cost allocation should not be either. MISO and SPP studies have both indicated that JTIQ projects benefit both load and generation and the cost allocation should reflect that. 

• Entitlements & congestion revenue rights: Entitlements and deliverability should be allocated to entities based on cost allocation.  The majority of costs (or all costs as recently proposed by MISO) will be paid by interconnection generation, but the hedging rights and entitlements would still be granted to load under MISO/SPP’s proposal.  These rights should rightfully go to entities based on cost allocation of the upgrades.  This aspect of the proposal further demonstrates that load is benefiting from upgraded projects without paying a commensurate share of the upgrades. 

• Lack of stakeholder input and transparency on the “New Direction”: Interconnection customers and other MISO stakeholders were completely excluded from discussions leading up to MISO’s “New Direction” proposal which significantly financially impacts interconnection customers. There is insufficient time for stakeholders to appropriately evaluate the substantial changes in the “New Direction” proposal for a Q1 2024 FERC filing timeline.

• Need for a cap on costs and oversight/review of any cost increases: CGA and APA have consistently expressed concerns that JTIQ transmission line costs are a “blank check” concept for high-cost, backbone transmission that incentivizes transmission owners to provide the highest cost option. Removing any allocation of cost to load (as recently proposed) further increases the concern for Generation Interconnection Customers. This provides an incentive to provide the highest cost option with no apparent review of costs or increases that are proposed. With a contingency fund already proposed and built into the costs for these lines, cost overruns above that contingency fund allocation continue to need both state and federal oversight and approval if an incentive to provide transmission at the lowest cost is to be realized, instead of at the highest cost as is currently proposed. SPP in their Consolidated Planning Process is taking historic interconnection costs and project viability into consideration when setting new rates and ensuring a backstop. MISO and SPP should consider something similar for JTIQ.

• Clarifying Limitations on a Transmission Owner Rate of Return for JTIQ Upgrades:  Although MISO’s November 15^th presentation provided little information on the presence of any rate of return on JTIQ projects, CGA and APA note that the previously identified cost responsibility framework should notallow for a return for the constructing utilities over the full project lifespan.  As previously proposed, MISO and SPP Transmission Owners will construct the JTIQ upgrades, and generators will pay for the upgrades as they come online in subsequent years.  This means that some rate of return on and of capital for the time period when transmission owners construct and own the upgrades may be appropriate; APA and CGA do not take a position at this time on whether the applicable return on equity for each transmission owner should apply to their JTIQ projects as well.  However, once generators have fully reimbursed a transmission owner for the costs of constructing the upgrades – including any applicable rate of return based upon the time period of utility ownership – the generators should not be responsible for any rate of return extending for the full operational lifespan of the JTIQ upgrades.  This would represent an unearned windfall for the transmission owners, as all capital invested in the JTIQ upgrades – as well as a rate of return, tailored to the duration of that capital investment – would be returned to them.  Based upon recent FERC precedent regarding unilateral transmission owner self-funding of network upgrades in NYISO, for HVDC upgrades in MISO, and in SPP, this would create a significant risk for FERC approval of cost allocation.  APA and CGA members fully support construction of the JTIQ upgrades, but would be forced to strongly oppose any long-term self-funding – which would be another form of uncapped costs on interconnection customers.

• Additional affected systems upgrades beyond JTIQ lines: Additional costs for transmission upgrades beyond JTIQ lines, that would reach multiple substations into the adjacent system based on varying voltage levels, would potentially be triggered at a higher incidence than is currently practiced with affected systems studies today, and with cost-adders not present in Affected System upgrades today, create significant uncertainty in affected system costs. The costs of lines that will need to be constructed in addition to the JTIQ fee, mean that the JTIQ fee may not provide the certainty in affected system upgrade costs that were a significant part of the benefit advertised when the JTIQ was proposed.  Self-funding should not be authorized for these lines since it is currently not allowed.  CGA and APA do not agree with this aspect of the JTIQ proposal and requests that it be adjusted to only reflect the current DFAX “trigger level” in SPP and current status of not permitting “TO Self-Funding” in SPP. 

• Additional Issues: CGA and APA have consistently provided feedback on additional issues in the proposal on JTIQ that have not been addressed previously. We continue to raise objections as noted in previous comments to MISO and SPP. These concerns include, but are not limited to:
• The trigger mechanism for the JTIQ fee does not meet the “but for” standard of generation interconnection upgrade responsibility since there is no assessment of the need for any of the JTIQ lines that is required for the fee to be owed by the GI customer;
• There has been no recent analysis of the benefit of the JTIQ lines to Generation Interconnection; 
• The costs assigned to the GI Customer are not related to the level of impact on any of the JTIQ projects, meaning that differences in impact by different GI projects are irrelevant to cost assignment;
• There is no analysis of whether these projects are the most cost effective projects for any GI customer;
• Some GI customers may have little or no need for these lines and have large additional upgrade costs to pay for GI and no analysis has been conducted, despite numerous requests, to allow the Generation development community to gain insight into whether the result of the JTIQ will increase the costs of interconnection for many GICs;
• There have been no mitigation measures proposed to address the long lead time needed to construct the JTIQ lines and the impact of in-service dates for GI customer projects, though the Customers are expected to be responsible for the JTIQ costs without having the information on curtailment of its resources until the lines are in service.  

• Need for an additional dedicated meeting to answer questions about the proposal: Given the many aspects of the JTIQ proposal presented at different times/meetings, it would be helpful for MISO and SPP to hold a dedicated workshop on the complete JTIQ proposal for stakeholder questions and concerns to be addressed.  

We appreciate MISO’s consideration of this feedback. 

Invenergy Comments to MISO’s Planning Advisory Committee (AC) on JTIQ Updated Approach

 December 6, 2023

 In the November 15, 2023, meeting of the Planning Advisory Committee (PAC), MISO presented an updated approach to several elements of the Joint Targeted Interconnection Queue (JTIQ) project portfolio. Those changes are outlined on slide seven of the posted presentation and include:

•            E&C cost allocation methodology

•            Operations & Maintenance

•            Backstop, and

•            Appendix G Entitlements

Invenergy appreciates the opportunity to provide the following comments in response.

E&C cost allocation methodology – Invenergy opposes a 100% allocation of E&C costs to generators.

As stated by MISO and SPP in their own “SPP-MISO Joint Targeted Interconnection Queue Cost Allocation and Affected System Study Process Changes” white paper (link), the goal of a JTIQ cost allocation methodology is to “equitably distribute the costs of the recommended transmission upgrades to those parties that are expected to benefit from the upgrades.”  The paper further reflects significant discussions between MISO, SPP and stakeholders to date which intends to achieve cost allocation to both generator interconnection customers and loads/transmission service customers that is “commensurate with benefits received.” [1]

MISO and SPP studies have both indicated that both generation and load benefit from the JTIQ projects. Yet, the RTO’s rationale for the change:

i.            Only recognizes the benefit of the JTIQ projects as serving to interconnect generators and fails to mention benefits to load.

ii.           Claims that by doing so, administrative complexity can be avoided, which scarcely can be considered a reasonable burden to justify in comparison to the higher cost generators will now be burdened with

iii.          Awards DOE funding to load first in order to offset load’s entirety of their allocation of costs at the expense of the generators.

The recently changed approach clearly fails to not only meet a just and reasonable threshold but also fails to achieve and live up to the RTO’s own previously stated objective, including the cost allocation methodology in the FERC approved Joint Operating Agreement between MISO and SPP for Interregional Projects.

For these reasons, Invenergy requests:

i.            DOE funding be applied pro rata commensurate with benefits to both generation and load, not sequentially to load first and then generators.

ii.           the RTOs provide support on the split of costs 90/10 and

iii.          pursue a methodology that meets the JTIQ objective and their JOA of allocating costs commensurate with benefits.

 Operations & Maintenance

Invenergy is supportive of MISO and SPP developing a common rate design whereby O&M costs are to be allocated to the constructing region.

 Backstop

Invenergy supports RTO’s proposal whereby backstop funding will be recovered in the constructing region, to reduce risk of one RTO supplementing transmission to the other.

 Appendix G Entitlements

Given our current understanding of the RTO’s proposal where generation will end up bearing the burden of an overwhelming percentage of the costs, yet entitlements and congestion rights would still be granted to load further suggests that the RTOs should rethink their cost allocation methodology.

Invenergy thanks MISO staff for their time and consideration.

[1] See Joint Operating Agreement found under MISO’s Rate Schedule 06 Section 9.6.3.2 https://docs.misoenergy.org/legalcontent/Rate_Schedule_06_-_MISO-SPP_JOA_and_CMP.pdf