The third time’s a charm for MISO getting FERC approval of its sweeping, cost-allocation overhaul for large economic transmission projects.
The commission on Tuesday accepted MISO’s proposal to lower the voltage threshold for market efficiency projects (MEPs) from 345 kV to 230 kV, add two new benefit metrics and eliminate the current 20% postage stamp allocation in favor of allocating full project costs to benefiting transmission pricing zones (ER20-1723).
In the latest iteration, MISO removed all mention of the local economic project category that FERC twice rejected. The small project type was a sticking point in the earlier filings because the commission took issue with a proposal to measure the value of such a project on a regional basis but cost-share only locally. The category was intended for smaller, economically driven transmission projects between 100 and 230 kV, in which 100% of costs would be allocated to the local transmission pricing zone containing the line. (See Local Projects Axed from MISO Cost Allocation Refile.)
Now such projects will again be consigned to MISO’s “Other Project” category, which has no regional benefits test and prescribes that smaller economically beneficial projects be allocated to the transmission pricing zone in which they are located.
In keeping with its previous orders, the commission found no problems with MISO’s plan to add new benefit metrics for savings if a project can reduce dependency on the RTO’s transmission contract path with SPP or eliminate needs for other reliability projects. The two new savings calculations will join MISO’s existing adjusted production cost savings metric in project evaluation.
“We find that the cost allocation resulting from the application of the three benefit metrics will be more precise at determining benefits,” FERC said.
The new rules will also provide limited exceptions to the competitive bidding process if a transmission project were needed immediately for the sake of reliability.
Dairyland Power Cooperative argued that the 230-kV threshold is still too high and “unduly discriminates against areas of the MISO footprint that do not utilize the 230-kV voltage class.” The co-op said MISO was dismissing the idea that smaller transmission projects could deliver regional benefits. It said 2018’s Old Dominion Electric Cooperative v. FERC — in which the D.C. Circuit Court of Appeals ruled that FERC erred when it prohibited cost-sharing for a class of high-voltage projects that demonstrated significant regional benefits — should be applied as caselaw, even for lower-voltage facilities in MISO.
But the commission pushed back on that assertion, saying, “Unlike the situation in ODEC, neither MISO nor the commission … has made the finding that MISO projects between 100 kV and 230 kV produce ‘significant regional benefits.’”
No 100-kV Threshold
FERC declined another request for a 100-kV MEP threshold in a separate order issued the same day (EL19-79).
LS Power last June asked FERC to compel MISO to lower the threshold for competitively bid transmission projects from 345 kV to 100 kV and outline a procedure for identifying beneficiaries. (See Complaint Seeks Bigger Role for Smaller MISO Projects.)
The company argued that “MISO’s transmission planning process fails to provide a path for development of regionally beneficial economic enhancements that do not currently qualify as [MEPs] and … this failure has resulted in unnecessary congestion costs and unjust and unreasonable rates.”
FERC pointed out that it just accepted MISO’s plan to lower the MEP voltage threshold to 230 kV. But even if it didn’t accept the allocation proposal, LS Power didn’t have a strong enough argument, the commission said.
“Although the concurrent … order lowers the market efficiency project voltage threshold to 230 kV, we nevertheless find that LS Power has failed to demonstrate that the then-existing 345-kV voltage threshold … and the current cost allocation method for economic other projects is unjust and unreasonable,” FERC said.
FERC said LS Power’s examples of hypothetical 100-kV projects that could benefit the footprint regionally also didn’t meet the burden of proof.