MISO has asked FERC for a month to prepare a defense of its second long-range transmission portfolio, which is being challenged by five state commissions in the footprint.
The grid operator said it needed an extension to respond to the 200-page complaint alleging that its $22 billion transmission package for the Midwest region isn’t as valuable as purported. As it stands, MISO is to respond to the complaint, filed July 30 by the public service commissions of North Dakota, Montana, Arkansas, Mississippi and Louisiana, by Aug. 19. The RTO asked for the deadline to be pushed to Sept. 19. (See Five Republican States File FERC Complaint to Undercut $22B MISO Long-range Tx Plan.)
MISO said it didn’t receive notice from the commissions that they planned to dispute the transmission portfolio. It also said it needed time to review testimony, conduct analyses and prepare its own expert witness testimony in response to testimony from William Hogan, research director of the Harvard Electricity Policy Group and professor emeritus at the John F. Kennedy School of Government at Harvard University.
Hogan testified that MISO’s assumptions and cost-benefit analysis “contain several significant defects,” including environmental benefits extended to states that don’t believe there is a social cost of carbon; reliability benefits premised on unlikely instances of load shedding as the alternative at a rate of $3,500-$10,000/MWh; and a distorted avoided capacity cost benefit that doesn’t imagine materially different and closer-to-load generation resources being built without the transmission projects. The criticisms track those that MISO’s Independent Market Monitor made in 2024. (See MISO Board Endorses $21.8B Long-range Transmission Plan.)
Hogan also said he took issue with the 29.8 GW of high-accreditation “flex capacity” MISO assumed would be built by 2042 to meet resource adequacy requirements despite no concrete plans from members. Hogan said if members built the nearly 30 GW in highly available capacity, it would obviate the need for scores of wind and solar generation projects MISO also assumed in its modeling.
MISO has said repeatedly that its second long-range portfolio is founded on the generation plans that its members have communicated to it. The RTO also noted that 75% of the footprint’s load is served by members with ambitious decarbonization or renewable energy goals.
The five state commissions asked FERC to deny MISO’s request for extension. They argued that MISO’s subject matter experts are in-house and “MISO should have on hand all the materials to support its case, primarily the package of information it presented to receive the board’s approval.”
They also said the filing should come as no surprise, because every concern they outlined with the transmission portfolio was raised multiple times by stakeholders, some state commission staff and MISO’s own Independent Market Monitor as the portfolio was being drawn up.
“MISO had ample time to respond to those concerns but failed to substantively address them,” the five state commissions said.
The states added that should FERC decide to grant an extension, it should be limited to two weeks beyond Aug. 19.
The North Dakota Public Service Commission — one of only two state commissions that joined the complaint that are expected to fund some of the long-range transmission — circulated a press release explaining that ballooning transmission costs drove their decision to draft the complaint.
“Transmission costs are rapidly becoming a large portion of utility customer bills, and their costs need to be carefully scrutinized,” Commissioner Jill Kringstad said. “I recognize the importance of transmission infrastructure, but it must be a prudent investment that balances affordability with the long-term needs of the grid.”
Commission Chair Randy Christmann said MISO gave a “weak justification” for the projects and that they will lead to “massive cost increases for residents.”
“Overturning MISO’s decision will protect North Dakotan consumers from this egregious maneuver,” he said.
Commissioner Sheri Haugen-Hoffart said she opposes “any cost allocation framework that compels states to subsidize transmission projects driven by other states’ public policy goals.”
“If a state chooses to pursue ambitious decarbonization targets, it should also bear the financial responsibility for the infrastructure required to meet those goals. Anything less undermines the principle of just and reasonable rates and imposes unfair financial burdens on ratepayers in states that have not adopted such policies,” Haugen-Hoffart said.
