The Mississippi Public Service Commission is using an audit of MISO membership to question whether Entergy Mississippi should remain a member, attracting blunt criticism from several renewable energy organizations.
The PSC opened the audit in April following February’s Winter Storm Uri and load shedding in MISO South. While it’s not unusual for the PSC to audit MISO membership, the commission’s language this time hints at a breakup with the RTO (2021-AD-52).
The Mississippi commission sought comments on the utility’s possible migration to the newly formed Southeast Energy Exchange Market and the savings it might achieve there, compared to the transmission construction costs of connecting to the new market.
The PSC also requested opinions on several MISO initiatives, including interconnection queue management, long-term transmission planning and future resource mix assumptions, its plan to raise the value of lost load from $3,500/MWh to $10,000/MWh, and a proposal to move to a four-season capacity auction and availability-based resource accreditation.
The commission also solicited feedback on the limited transfer capability between MISO Midwest and MISO South.
Finally, the commission said it was looking for any other “deal-breakers … that would make it unreasonable or cost-prohibitive for Entergy Mississippi to be an RTO member.”
“While [Entergy Mississippi’s] analysis indicates that historically RTO membership has produced significant benefits for customers, it is less clear to this and other commissions whether the long-term benefits of RTO membership exceed the long-term costs and commitments of RTO membership, especially given that the RTOs’ (including MISO) structure, services and membership continue to change significantly,” PSC Chair Dane Maxwell wrote.
Fellow Commissioner Brandon Presley said in March that Mississippi regulators should examine the fairness of MISO’s February load-shedding orders and “correct” other problems that exist within the RTO. (See “Mississippi PSC Unhappy,” MISO Underscores Need for RA Action in Winter Storm Review.)
In public MISO meetings, PSC staffer David Carr and Washington, D.C.-based commission consultants Bill Booth and Nick Puga have voiced opposition to MISO’s long-range transmission plan. Entergy Mississippi consultant Dave Harlan, constantly in touch with the commission, has questioned MISO’s predictions of a renewable-heavy resource mix. (See Entergy Consultant Under Fire for Covert Role in MISO.)
The fiercely worded audit is unlikely to force Entergy Mississippi’s exit from MISO. The utility filed comments that indicated it had no qualms about its membership. It said MISO has been able to deliver benefits for its customers and it will probably continue to do so.
The utility said that it is in the public interest to continue its MISO membership for the “foreseeable future.” Entergy estimates it has saved $246 million in energy and capacity-related costs since joining the RTO in late 2013.
Harsh Words from Renewable Advocates
The Southern Renewable Energy Association (SREA) and other renewable power organizations didn’t mince words over their opposition to the PSC’s questions.
“Mississippi is saving tens of millions of dollars every year by staying in MISO and no analysis publicly exists to show otherwise,” the SREA wrote. “While staying in MISO clearly has its benefits, Mississippi is not maximizing its membership. The state is spending millions of dollars every year on expensive out-of-state consultants to slow improvements at MISO.
“Previous positions by Mississippi Public Service Commission staff and consultants have stalled large scale transmission expansion efforts for many years. SREA recommends that Mississippi take a more proactive role in promoting transmission expansion and generation interconnection fixes at MISO,” the organization said.
SREA added that “Mississippi ratepayers are literally making millionaires out of D.C. lawyer consultants that work to slow transmission development and restrict energy market competition.” The group requested the PSC hire an independent third party to perform a “multiple scenario quantitative and qualitative analysis” to weigh Entergy’s RTO membership options.
Incumbent utilities “employ a variety of tactics including threatening to depart the system, filing complaints at FERC, slowing down processes that would increase competition to the benefit of the ratepayer, or lobbying for passage of anti-competitive legislation” to further their interests within RTOs, SREA said.
“MISO staff will not publicly name names, document offenses, or share publicly all the specific examples of subterfuge by its own incumbent utility members that are working to oppose MISO’s independence … SREA anticipates MISO will take a simple position of providing monetary and qualitative benefits of membership, without some of the straight talk desperately needed to fix Mississippi’s role and relationship with MISO,” the organization said.
SREA also noted that the Department of Justice’s investigation into Entergy’s anti-competitive behavior — a case that spurred Entergy into RTO membership a decade ago — remains suspended, but open. It suggested that an Entergy Mississippi exit from MISO would pique the department’s interest as to whether Entergy was again restricting access to the wholesale market.
The Sustainable FERC Project said Entergy Mississippi isn’t maximizing the benefits of its MISO partnership and said the commission “should consider how to more productively engage in MISO’s planning process to increase the benefits to Mississippi customers.”
Clean Grid Alliance agreed that the utility “has attempted to hinder progress at MISO, particularly in transmission planning.”
The MISO interconnection queue contains 2 GW and $2.7 billion worth of renewable generation under development in Mississippi. The Alliance said further renewable development in the state could be a “game-changer for rural Mississippi.”
CGA also said if Entergy Mississippi or all Entergy companies joined the newly formed Southeast Energy Exchange Market, its customers would almost certainly see bill increases. It said Entergy should consider SPP membership before it moves to the fledging southeastern exchange.
“Currently, Entergy does not have any physical ties to MISO North, and the tie between MISO North and MISO South is very constrained, with only 1,000 MW of firm contract capacity. On the other hand, Entergy has over 40 physical ties with SPP totaling 14,000 MW. Thus, the Entergy system would be more physically integrated into the SPP RTO than it currently is in MISO,” the CGA wrote.
SREA said Entergy appears to be fond of the constricted Midwest-to-South flows.
“Many observers have noted that Entergy’s selection of MISO has enabled the utility to maintain maximum control over the region, while reducing Entergy’s exposure to competition,” the organization said. “Joining MISO has not curtailed Entergy’s anti-competitive business practices. As long as the North/South intertie remains restricted, Entergy will exert near total control over the MISO South region.”
Climate activist group 350 New Orleans said an investigation should be opened into “whether certain actions or inaction on behalf of [Entergy Corp.] subsidiaries in the MISO South subregion have resulted in placing a limitation or obstruction to benefits, reliability, and competitive electric service to the region.”
350 New Orleans pointed to the interconnectedness of MISO South and noted that it and Louisiana depend on the Grand Gulf Nuclear Power Station in Port Gibson, Miss.
“Given that this resource is a central component in resource plans throughout many years for Entergy Corp. subsidiaries in MISO South, any discussion related to subsidiaries leaving MISO relates to resources that ratepayers in New Orleans and the state of Louisiana are reliant on,” the group wrote.
MISO, an intervenor at the request of the commission, predictably touted the cost savings Entergy has achieved under its supervision. The grid operator said it saved its members a collective $3.1 billion to $3.9 billion in 2020 compared to their going it alone on the grid.
The RTO said all of its transmission planning and resource adequacy initiatives are vetted with stakeholders and necessary to the continued reliability of the footprint. It pointed out that its value of lost load has been unchanged for 10 years.
MISO also said it will continue “to evaluate cost-effectively increasing the transfer capability between the MISO Midwest and South.”
