By Rich Heidorn Jr.

FERC on Wednesday rejected MISO’s proposed cost allocation plan for interregional projects outside the RTO, saying it had not demonstrated the reasonableness of the methods detailed in the proposal (ER17-387).

Under MISO’s joint operating agreements with PJM and SPP, a transmission project can qualify as interregional even if it is in only one of the two neighboring RTOs, as long as it provides benefits to the other. MISO said that although no such projects are part of its Transmission Expansion Plan, interregional studies currently underway could result in such projects.

Proposal

In its filing last November, the RTO proposed that its portion of costs from an:

• Interregional reliability transmission project terminating wholly within SPP or PJM — that is, with no interconnection to any MISO transmission facility — be allocated to those entities who would have paid for the MISO regional transmission projects that the interregional project avoids;
• Interregional economic transmission project terminating wholly outside MISO be allocated 100% to the benefiting local resource zones based on adjusted production cost savings (interregional reliability projects terminating wholly within SPP that provide economic benefits to MISO would be allocated in the same manner); and
• Interregional public policy transmission projects terminating wholly outside MISO be allocated to parties who would have paid for the MISO regional projects that the interregional project supplants.

The RTO intended to use the method only until the end of its five-year Entergy integration transition period, which ends in December 2018.

In approving Entergy joining MISO, the commission accepted a revised planning and cost allocation framework with two planning areas, one covering the pre-existing MISO members and a new second planning area (MISO South) including Entergy. The RTO said the transition was necessary because transmission planning for the existing MISO footprint and MISO South had not been done under a common process using the same criteria.

The transition cost allocation rules, which eliminated MISO’s footprint-wide postage-stamp method, are spelled out in Attachment FF-6 of the the RTO’s Tariff.

The RTO said that without the changes it proposed in November, interregional transmission projects wholly outside the MISO footprint would be allocated under Attachment FF. The costs of an interregional economic transmission project that terminates wholly outside of MISO would use the non-transition market efficiency project cost allocation: 80% to the benefiting zone, 20% postage stamp across the entire MISO footprint. The RTO said that would violate the intent of Attachment FF-6.

FERC Misgivings

FERC first indicated its misgivings with the proposal in a deficiency letter in January, which asked MISO to explain why it was just and reasonable to apply different cost allocation methods based solely on the location of the interregional project.

But the commission ruled that the RTO failed to demonstrate that its proposal would allocate costs in a way “that is at least roughly commensurate with the benefits received.”

“Notwithstanding the fact that the commission has determined that both [multi-value projects (MVPs) and market efficiency projects (MEPs)] provide regional benefits and are appropriately cost-allocated regionally, at least in part, MISO proposes to eliminate the regional cost allocation component for its share of market efficiency projects and multi-value projects that terminate wholly outside MISO,” the commission said. “However, MISO provides no evidence or analysis to demonstrate that the benefits of interregional transmission projects that terminate wholly outside MISO … accrue to a more narrow range of customers than the benefits of any other multi-value project or market efficiency project, including those that physically cross the seam between MISO and another transmission planning region.”

FERC rejected the RTO’s contention that it had previously approved similar cost allocation methods, saying that most of the proceedings cited by the RTO addressed interregional cost allocation methods. “Here, however, MISO is not proposing an interregional cost allocation method; it is proposing regional cost allocation methods that it will use to allocate within MISO the portion of the costs of interregional transmission projects.”

FERC said that although it has approved avoided-cost-only interregional cost allocation methods and an avoided-cost-only regional cost allocation method for reliability projects, “the commission has not previously addressed whether a transmission planning region may use an avoided-cost-only regional cost allocation method for public policy-related transmission projects.”

“This is consistent with the commission’s previous explanation that because Order No. 1000 has different requirements for regional transmission planning and interregional transmission coordination, a just and reasonable interregional cost allocation method may nevertheless be an unjust and unreasonable regional cost allocation method.”

Stakeholders Split

FERC’s rejection means that the issue will return to MISO, where it has divided stakeholders. FERC said the RTO told the commission that if its proposal was rejected, it would not apply the non-transition period cost allocation methods under Attachment FF to interregional projects outside the RTO, “and therefore will have to revisit this issue with its stakeholders.”

MISO told FERC that about half its stakeholders supported the revised Attachment FF-6 while the other half wanted to retain the non-transition period MEP cost allocation in Attachment FF for interregional economic projects entirely outside of the RTO.

Because it rejected MISO’s filing, the commission said it did not have to address protests by the New Orleans City Council, E.ON Climate & Renewables N.A. and EDF Renewable Energy.

The two renewable companies complained about MISO’s criteria requiring MEPs be rated at 345 kV or higher and meet a 1.25:1 benefit-cost ratio, saying they were impeding the development of MEPs. They asked the commission to reject the RTO’s proposal or condition its acceptance on removing the 345-kV threshold and lowering the benefit-cost ratio to 1:1.

New Orleans contended that a MISO analysis had shown that individual transmission owners in benefiting local resource zones may not always receive production cost savings from sub-345-kV economic transmission projects.

The commission also declined to respond to regulators from Arkansas, Louisiana and Mississippi, who sought clarification about which cost allocation methods would apply if the commission rejected the RTO’s proposal.

“MISO states that it will revisit the issue with stakeholders if its proposed cost allocation methods are rejected, and we will afford MISO the opportunity to do so,” the commission said.