By Amanda Durish Cook

Clean energy advocates are asking MISO to make comprehensive changes to its transmission planning to help ensure the region can continue an uninterrupted shift toward renewable resources.

Among the requests from the Environmental and Other Stakeholder Groups sector: that the RTO revise its future scenarios, synchronize interconnection and planning studies, and re-evaluate interconnection upgrade cost allocation.

Renewable projections under current futures used in MISO’s Transmission Expansion Plan (MTEP) are “far too conservative,” Clean Grid Alliance (CGA) consultant Natalie McIntire said in an interview with RTO Insider.

“If you look at the four futures, only the most aggressive future is an accurate depiction of what’s happening today,” CGA Executive Director Beth Soholt said. “In other words, we’ve blown past those futures. So, MISO isn’t planning for the future, much less planning for today.”

The four futures estimate that MISO’s resource mix will consist of a 15 to 35% share of renewables by 2033. But stakeholders for months have been criticizing those estimates as seriously underestimating the widespread adoption of renewables. Several have said the RTO’s predictions are resulting in inadequate new transmission projects and leaving renewable developers with prohibitively expensive interconnection upgrades as system patches. (See More MISO Members Join Call for Tx Planning Change.) MISO has said its large interconnection queue means that the “scope and costs of network upgrades are expanding.”

MISO is now developing a straw proposal on new futures development for stakeholder review at an Oct. 17 workshop. The new futures will be in place for MTEP 2021, and the RTO will use a slightly updated version of its MTEP 19 futures for its 2020 cycle of transmission planning.

The Union of Concerned Scientists’ Sam Gomberg said he generally thinks the four scenarios have been thoughtfully constructed.

“In terms of structure, I think the futures don’t need to look radically different. The structure is sound,” he said.

It’s the content that concerns him.

“The futures are not living up to this ‘bookend’ framing,” Gomberg said, using an oft repeated word among MISO planners. “They’re not planning in the futures for what is coming.” He said the RTO needs to consider both widespread renewable participation and a “carbon constraint umbrella.”

Members of the Environmental sector have also called for one or more futures to model carbon regulations.

“Maybe I’m living in my own environmental echo chamber, but if the political winds shift, what we’re talking about is getting to 0% carbon emissions by 2050. Decarbonizing the electricity sector by 2050 is a real possibility,” Gomberg said.

The growing grassroots momentum to address climate change also can’t be ignored, Gomberg said, with or without a federal government willing to draft a carbon cap policy.

“These [policy] conversations slowed down, and MISO staff for a couple of years maybe felt like they had a justification to slow down and wait for some kind of carbon cap,” Gomberg said. “We can’t be sure what shape it’s going to take … but we can be very sure that’s there going to be some type of limit. I don’t want MISO to be caught off-guard on the pivot.”

Increasing Complexity

“MISO likes to plan around certainty,” Soholt noted, adding that the RTO accounts for state statutes and orders from state commissions but could be overlooking municipal and corporate renewable commitments and carbon targets, as well as utilities’ request for proposals.

“There’s all this mismatch of things that MISO isn’t taking into account. We’re always going to be in a chicken-and-egg situation if MISO doesn’t expand their bookends and reflect reality,” she said.

It’s not simply a matter of waiting for the expiration of the investment and production tax credits to expire so transmission planners can get back to business as usual, Gomberg said.

“The numbers that I’m seeing say wind and solar are still going to be the cheapest resources out there. There’s going to be other developers ready to fill that void,” he said.

MISO might be underestimating in its future how electrification might stimulate the currently flat demand for energy, McIntire added. “If not right now, we see that demand might grow in the next five to 10 years.”

Gomberg also said MISO should more closely evaluate the effects of nuclear plant retirements in the 2030-2035 time frame as plant owners are faced with choosing between a license extension or retirement.

Soholt expressed concern that MISO’s renewable estimates could lead to a system “funded on the backs of interconnection customers, which naturally raises questions of who can reap the benefits of such projects.”

McIntire said interconnection customers don’t receive financial benefits from transmission investments comparable to the rate of return that the RTO’s transmission owners receive.

“They’re not getting benefits commensurate with the costly transmission upgrades interconnection customers are having to construct,” she said. “And if load ultimately pays, we want the transmission planning and interconnection process to consider what’s most cost efficient for ratepayers. We would suggest that constructing a transmission grid with a whole lot of lines paid for by interconnection customers is not fair or efficient. Comprehensive transmission planning with much more realistic future scenarios is a more cost-effective way to build out the MISO grid.”

“It’s not just a little tie-line; it’s not just a substation upgrade,” Gomberg said, stressing that interconnections have now become regionally beneficial to the system.

McIntire pointed out that MISO also separates interconnection upgrades from other transmission project types in such a way that cost allocation is the burden of interconnection customers only.

That existing process is blind to the fact that many others in MISO benefit from interconnection upgrades, she said.

“We all know transmission will bring a variety of benefits to a variety of beneficiaries,” McIntire said, calling for a “more holistic” cost-benefit analysis on interconnection upgrades.

Synched

McIntire also said MISO’s interconnection upgrade studies and transmission planning studies should move on the same schedule and draw on the same study assumptions.

“There’s a bit of a timing disconnect in that we have generator interconnection studies on one track and MTEP planning studies on a different track,” she said.

McIntire said MISO is in a position where it could reject a congestion-relieving transmission project, believing the congestion will be taken care of through an interconnection upgrade attached to a proposed generation project. However, interconnection upgrades can disappear as developers withdraw project proposals from the queue. McIntire said it’s not fair to assign the costs for an interconnection upgrade simply based on which of these study processes finishes first.

“Because those processes are done in silos, they’re cutting some projects off at the knees,” Gomberg said. “The left hand isn’t talking to the right hand to some degree.”

McIntire also said transmission planners should be looking to the queue as an indicator of where developers will site new resources.

“The queue is a good indicator of what will occur,” CGA Regional Policy Manager Sean Brady agreed.

“It’s always been that not all the projects in the queue get built. That’s a fair thing to say,” Gomberg said.

Though not perfect, the queue is a “strong indicator” of where resources will get built because often another developer comes in with plans in the same area, Gomberg said. The fact that all of the projects in the queue don’t get built shouldn’t be used as an excuse to say there’s too much uncertainty to move forward in the planning process, he added.