Tensions have been building among MISO stakeholders over what some perceive as an undercover Entergy plant in stakeholder meetings.

At the center of the controversy is Veriquest Group President David Harlan, a former Entergy executive and regular attendee of MISO transmission planning meetings.

On Sunday, renewable energy advocacy group Energy and Policy Institute accused Entergy of placing Harlan in MISO stakeholder meetings to espouse the utility’s ideas without the company connection, citing public records it obtained. The group suggested that Entergy may have hired him to influence MISO policy away from renewable development in order to safeguard its coal and gas plants. “Entergy may have been worried about low-cost wind energy in MISO displacing the company’s expensive legacy coal and gas units, impairing its ability to justify construction of new power plants,” EPI said.

Entergy: Nothing to Hide

Although Harlan had refused to identify his clients during meetings in 2019 and 2020, Entergy on Tuesday confirmed its association with him, telling RTO Insider there was nothing wrong with how he conducted himself.

Entergy Mississippi “has a longstanding working relationship with Dave Harlan and Veriquest Consulting,” an Entergy spokesperson said. “Mr. Harlan is a retired Entergy employee. [He] has made no secret of his time working with Entergy and his representation of Entergy Mississippi is well known within MISO circles. He advocated on the company’s behalf in the MISO stakeholder process, and, contrary … to insinuations, there’s nothing improper or unusual about those efforts.”

Entergy’s statement confirmed what some MISO members believed, said one stakeholder who asked not to be identified.

Use of a covert consultant does not appear to violate any MISO rules, however.

MISO’s Steering Committee debated throughout the year — but ultimately decided against — proposing a new rule that would require consultants to identify the clients they represent when participating in stakeholder meetings. The RTO’s Stakeholder Governance Guide does not contain a rule against the practice. (See MISO Weighs Rule on Consultant Transparency.)

The Steering Committee has instead advocated for committee chairs to be empowered to manage discussion based on the “norms” of their committees.

Stakeholders took notice after Harlan repeatedly refused to disclose his clients over multiple meetings of the MISO Planning Advisory Committee in 2019 and 2020. When Harlan offered opinions or asked MISO planners for more examination of their planning inputs, he has sometimes insisted that he is simply acting on his own behalf.

Questioning Planners’ Assumptions

Harlan repeatedly questioned MISO transmission planners’ assumptions on renewable generation growth, especially in MISO South. He has argued that renewables will not be able to carry the region’s industrial load as effectively as existing baseload generation.

Before forming Veriquest in 2008, Harlan, an engineer and MBA, worked for Entergy for 17 years. His last job was senior vice president for system planning and operations, following stints as vice president for strategic planning and special projects and vice president of marketing. He did not respond to RTO Insider’s request for comment.

The Steering Committee in May leaned toward drafting general language supporting stakeholder transparency rather than imposing a strict rule that consultants be forthcoming about their clients. The committee has avoided mentioning Harlan by name, as other consultants have participated in the MISO stakeholder process without first disclosing clients publicly.

“I think the Steering Committee is hesitant to put some strict rules in place regarding consultants, but there could be some language that says, ‘Hey, transparency is paramount to the stakeholder process,’” Resource Adequacy Subcommittee Chair Chris Plante of WEC Energy Group said at the Steering Committee’s meeting June 10.

Market Subcommittee Chair Megan Wisersky of Madison Gas and Electric said it was unnecessary to enact a new rule on consultant transparency.

“I see this as a matter of professional courtesy. And it’s just that. I don’t want to see professional courtesy codified in the Stakeholder Governance Guide,” Wisersky said.

Discounting Comments

Plante also said a rule was unnecessary, though he warned that stakeholders unwilling to disclose whom they represent might be dismissed by others.

“I discount their comments. From my perspective, if they’re not willing to announce their client, I take their comment less seriously,” Plante said.

MISO’s Advisory Committee discussed mandatory consultant identification at its closed executive planning session Nov. 2. The committee acknowledged that the issue arises mostly in PAC meetings. PAC Chair Cynthia Crane has promised a follow-up on the issue at the committee’s January meeting.

Entergy’s spokesperson said Harlan has abided by MISO requirements and that “his client’s identity was known to MISO, to our regulators and to many stakeholders, as well.”

“In addition, Mr. Harlan’s advocacy with MISO was part of a larger effort by Entergy Mississippi to work alongside regulators and other stakeholders to advocate for transmission planning and cost allocation approaches that we believe are in our customers’ best interests,” the spokesperson said.

Communications with Mississippi PSC

Emails from Harlan to Mississippi Public Service Commission Special Counsel David Carr, obtained by EPI, confirm that Harlan makes comments on behalf of Entergy and collects information in MISO meetings to pass along in the company’s strategy meetings. They also appear to show that Harlan sometimes voices the positions of the Mississippi PSC as well as Entergy Mississippi.

In one email Sept. 25, 2019, Harlan asks if he is accurately representing the stances of both Entergy Mississippi and the Mississippi PSC. “Please let me know if any of my comments were perceived as contrary to the common or best interest of MISO South customers, [the Mississippi PSC] or [Entergy Mississippi],” he says. “I need to be aware of any concerns so I can limit or reframe my comments in future discussions.”

He also reports that he received “pushback in and outside of meetings seeking to silence or restrict my oral comments, from the renewable lobby and probably a MISO North regulator and some transmission developers.” In the same email he says he “resisted efforts … from MISO and some stakeholder [sic] to identify my clients before making a comment.”

“My comments at MISO meetings always seek to raise issues for thought and to promote better visibility, transparency and objectivity in the MISO discussions and planning processes,” he tells Carr. “I never represent that I speak for [Entergy Mississippi] or [the Mississippi PSC], but rather as a MISO South customer and an adviser to multiple MISO South stakeholders.”

Harlan sent the email after Clean Grid Alliance’s (CGA) Natalie McIntire appeared at the Sept. 23, 2019, PAC meeting to sound the alarm about increasingly pricey network upgrades for the mostly renewable generation in MISO’s interconnection queue. (See More MISO Members Join Call for Tx Planning Change.) He writes that his comments on the presentation “were not made on behalf of a specific client but to address issues of clarity or objectivity about the CGA proposal.”

“Since no other MISO South entity made comments, I felt that CGA[’s] comments needed some timely injection questioning some of their logic.”

Harlan says that CGA is “launching a full-court press to build transmission for wind delivery from MISO North and have load pay for transmission costs for both local and distance delivery.” He speculates that the Midwestern Governors Association and some MISO Midwest state regulators and utilities were also behind the push for new transmission to enable renewable generation.

In early October 2019, Carr wrote that PSC staff would discuss Clean Grid Alliance’s presentation with Entergy Mississippi using information collected by Harlan. In a May 2019 email, Entergy Mississippi Vice President of Regulatory Affairs Jeremy Vanderloo gives Carr a heads-up that Harlan would be raising Entergy Mississippi’s concerns about the cost allocation of some transmission projects in MISO’s 2019 planning cycle at a MISO South subregional planning meeting.

Entergy has used backdoor channels to advance its agenda before. In 2018, Entergy New Orleans contracted with public affairs firm The Hawthorn Group to arrange for paid actors to show up at New Orleans City Council hearings in support of a proposed $210 million natural gas plant. Though the council placed a $5 million fine against the company for the scandal, it ultimately approved the Michoud Plant.