In its complaint against PJM and MISO (EL13-88), the Northern Indiana Public Service Co. proposed the following changes:

1. The MISO-PJM cross-border planning process should run concurrently with the MISO Transmission Expansion Plan (MTEP) and PJM Regional Transmission Expansion Plan (RTEP) planning cycles, rather than after those regional planning cycles. NIPSCO proposes a schedule to have the interregional planning process run concurrently with the regional planning process.
2. There should be consistency between the PJM and MISO planning analysis. While the RTOs have regional differences, both entities should be consistent in their application of reliability criteria and modeling assumptions.
3. MISO and PJM should have a common set of criteria for the approval of cross-border market efficiency projects. The current and proposed changes to the JOA do not streamline the process but instead add delays, complications, and further administrative hurdles.
4. The criteria for approval of a cross-border market efficiency project should be amended to address all known benefits including, more specifically, avoidance of future market-to-market payments made to reallocate short-term transmission capacity in the real-time operation of the system.
5. MISO and PJM should be required to have a process for joint planning and cost allocation of lower voltage and lower cost upgrades for cross-border projects.
6. MISO and PJM must improve the processes within the JOA with respect to new generator interconnections and generation retirements.

(See related story, FERC to Look Over PJM’s, MISO’s Shoulders at Joint Talks.)