PSC: Expedited Project Review Process Questions (PAC-2024-1) (20240501)

WEC Energy Group recommends that PAC continue to review and approve Expidited Project Review requests but allow that review and approval outside of the regularily scheduled PAC meetings.  By the time an EPR reaches the PAC, it has been assessed by both MISO and stakeholders through the Subregional Planning Meetings.  The PAC approval is largely administrative but an important step in the process.  The sector PAC representatives should have the ability to review, ask questions, and approve an EPR outside of the PAC meetings via email, or if issues are identified, through an out-of-cycle scheduled PAC meeting.

DTE appreciates the opportunity to provide feedback on this topic. Here are shown below:

• Would members support a fee for this process (at cost and applicable to all submittals)? DTE does not support a fee for this process. The current regulatory construct for DTE does not allow to charge or pass this cost to our customers.
• Please elaborate the services expected if a fee were implemented. See DTE previous answer. In addition, it is not clear how a fee would resolve some of the concerns that were brought up which triggered the prosed changes to the current process.
• We heard interest for a bi-monthly process (6 per year). What other timeframes would meet member needs? DTE in general would be supportive of the bi monthly process provided that the deadlines are being met and completion is not missed.
• What are recommendations on how to approve EPRs outside of a PAC meeting? Email approval from PAC leadership can be considered in lieu of an actual meeting.

Transmission Owners Feedback on EPR Process Improvements

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The MISO Transmission Owners (Owners) appreciate MISO’s efforts to improve the EPR process, as we understand the landscape is changing with a higher amount and in some cases more complex projects being submitted through this EPR process.  However, the study and approval of EPR projects in a timely manner is an important core MISO function.  In response to the additional questions posed at the May 1 PSC, the Owners have the following comments:

1. Would members support a fee for this process (at cost and applicable to all submittals)?  This would be an “at cost” fee.

The Owners do not support a fee for this process.  MISO’s timely approval of EPR projects is a core MISO function.  Appendix B of the Owners Agreement states: “MISO shall develop a streamlined approval process for reviewing and approving projects proposed by the Owners so that decisions will be provided to the Owner within thirty (30) days of the projects submittal to MISO unless a longer review period is mutually agreed upon.”  MISO’s approval of “[a]ny plans that call for modifications to the Transmission System” is restricted to cases that “significantly affect ATC [Available Transmission Capacity].” As a core function, it is not appropriate to impose a discreet fee for this process.   MISO already recovers its costs pursuant to Schedule 10 of the MISO Tariff.   

Maintaining reliability through transmission planning is MISO’s fundamental purpose.  As the Owners of the Transmission System in the MISO region and the majority of the load serving entities that pay Schedule 10 to fund MISO functions, if MISO needs additional staff to perform its planning responsibilities, the Owners support MISO adding staff to meet its obligations. 

2. Please elaborate the services expected if a fee were implemented.
   As noted above, the Owners do not support a fee for these services. 
   
   
3. We heard interest for a bi-monthly process (6 per year). What other timeframes would meet member needs?
   If having timing certainty is a main driver behind MISO proposing these process changes to EPR review, then the Owners recommend establishing a monthly process to meet MISO’s obligations under Appendix B of the Owners Agreement.  Submittals could be due on a specific calendar day in order for MISO to process them in that month, in accordance with the current BPM language.  Any projects submitted after the monthly cut off would then wait until the following month for MISO to process.  Setting a monthly cut-off date would provide MISO certainty about when any EPRs will be submitted and allow MISO to use one updated model for each monthly review. 

For projects that are not changing system topology and clearly do not affect ATC, such as a road move or like-for-like replacement, the Owners re-iterate the suggestion for either a “fast-track” or an after the fact MTEP submittal rather than the standard EPR submittal to further reduce the number of EPR project reviews needed.  In addition, adjusting the $1M threshold for projects that would need to be submitted through the EPR process could be another option to reduce the number of requests.  It is clear that that dollar threshold was established quite a number of years ago and does not reflect the current cost environment. 

For the more complex and larger projects such as large economic development spot loads, today the Owners do a lot of the study work internally before submitting to MISO to review.  If a prescriptive set of modeling requirements and study parameters used for this internal analysis was established, and the Owner submitted their internal study results to MISO for their prudency review of the project, if this would further relieve some the resource burden on MISO.  This could potentially involve the use of a MOD project file and MTEP portal project information if MISO determined this would streamline their review and avoid re-creating much of the work the TO has already performed.  The Owners propose this methodology change as a way for MISO to better and more consistently leverage the work the Owners are already doing in order to streamline the efforts MISO must take to verify the Owners’ study results. 

4. What are recommendations on how to approve EPRs outside of a PAC meeting? 
   The Owners remind MISO and stakeholders that the PAC is not explicitly approving the EPRs. Approval of EPRs is a MISO function under the Owners Agreement.  A stakeholder process to review the EPR projects in the TSTF and PAC meetings is for stakeholder transparency.  To that end, the Owners suggest a standing monthly MISO-wide TSTF meeting followed by a PAC EPR review only meeting for stakeholders to ask questions.  Both standing meetings could be cancelled if there is no EPR in that month.  Establishing a standing monthly meeting would be an improvement over the current meeting cadence of PAC meetings approximately every 6 weeks and regional TSTF meetings scheduled on an ad hoc basis.

The Owners look forward to continuing to work with MISO and stakeholders to develop a solution that meets all the needs of members and their customers and that considers the current environment of project development. 

WPPI would suggest that MISO consider bi-monthly process to reduce delay that would be possible with a quarterly process.

WPPI would support a fee for this process to the extent this would facilitate timely processing that MISO could not otherwise reliably accommodate.

WPPI agrees with WEC’s posted comments that PAC review can occur outside of regularly scheduled PAC meetings, which are now often several weeks apart.