MISO’s Planning Advisory Committee continued discussion Wednesday on a revised planning futures process that will help the RTO develop transmission needed to comply with the Clean Power Plan.
Durgesh Manjure, MISO’s manager of resource adequacy coordination, said the final CPP plan will be incorporated into the MISO Transmission Expansion Plan beginning with the 2017 cycle. The MTEP 16 futures are based on the draft rule, which was changed significantly.
“Futures for the next few MTEP cycles are expected be driven largely by the CPP. Work done for MTEP 17 should allow for more efficient development of MTEP 18-plus futures,” MISO wrote in a presentation.
MISO “believe[s] it’s appropriate to bring in the Clean Power Plan to the MTEP 17 cycle,” even though implementation itself isn’t slated to begin until 2022, Manjure said. States are required to submit a compliance plan or an extension request in September 2016 with final plans due in September 2018.
While MISO said incorporating the CPP final rule into MTEP16 “could be beneficial,” there are ultimately no plans to revise MTEP16 futures to reflect the final rule.
Stakeholders have said that drivers used for MTEP futures should not be limited by existing policies and include policies on the horizon. They also asked that MISO share historical and forecast data on key variables before workshops take place.
Transmission-owning stakeholders requested that MISO review its resource siting process. The RTO said siting is to be reviewed in the coming year.
“It’s a journey of discovery,” Manjure said, quoting MISO executive vice president of transmission and technology Clair Moeller’s stance on CPP preparation. “By no means are we jumping the gun on MTEP 17. This is a precursor to the conversation,” he added.
Under the realigned MTEP futures development, MISO will share relevant historical and forecast data at the beginning of an MTEP cycle, then check if the existing futures sufficiently capture the economic and policy landscape for long-term transmission planning, reusing them if appropriate. The RTO will also actively look for any new sensitivity scenarios and plan to reuse resource expansion and siting in successive PROMOD models. PROMOD models themselves will be updated annually to represent the latest topology in MISO’s footprint.
“The timeline and overall process definitely warrants a look,” Manjure summed up.
Manjure said the revised planning futures process will be subject to “ongoing discussions” at upcoming PAC meetings; no voting date has been set.
Proposed Changes to Expedited Project Review Fall Short, Stakeholders Say
The PAC continued its review of MISO’s proposed changes to the out-of-cycle review process, with some stakeholders complaining that the changes don’t address their concerns that expedited projects could undercut competition under FERC Order 1000.
The RTO is drafting changes to its business practices in response to the uproar earlier this year over Entergy’s $200 million out-of-cycle project in Louisiana.
MISO defended its proposal to eliminate detailed criteria defining expedited projects, saying it did so because the RTO does not have the authority to challenge load-serving entities’ load assumptions or regulatory drivers. MISO said it would consider adding more detailed criteria “provided that those bounds do not require MISO to challenge the obligations of the LSE or [transmission owner].”
“We really believe that the best mechanism to address these types of issues is transparency,” said Matthew Tackett, a MISO principal advisor.
MISO also said the PAC does not have the authority to order planning staff to report to MISO’s Board of Directors on expedited projects. MISO staff reports to the board at its own discretion.
“Of course we will consider [recommending] these projects if there’s an appropriate need and if the timing is appropriate,” Tackett said.
Stakeholders argued that under the proposed changes, MISO and the PAC can do little to prevent TOs and LSEs from inflating their load demands and proposing an expedited project under false pretenses. One PAC member said it would be “troubling” if MISO chooses to interpret the Tariff language narrowly and ignore stakeholder concerns.
Another said the revision process had become “a very frustrating exercise” because redline suggestions to the manual language have not been accepted by MISO.
Discussion on the process will wrap up at December’s PAC meeting, when the committee will be asked to approve the changes.
Queue Remodel Moves to Final PAC Review; Stakeholders Request Transition Plan
MISO expects to draft final Tariff language for its interconnection queue reform effort in the coming month.
The proposed changes, which include the introduction of phases and related fees along with a reduction of restudies, drew criticism from stakeholders at last week’s PAC meeting. Stakeholders representing wind power developers were particularly critical of the plan, saying it could increase their costs to $25,000/MW for projects that may not come to fruition.
The last revision of queue rules was completed in 2012.
“We have made changes over the past, but they’re not going as well as we envisioned, so this is our chance to go back and fix it,” Vikram Godbole, senior manager of MISO’s generator interconnection planning group, told the committee.
Under current rules, Godbole said, customers may leave their interconnection projects in the existing queue even if they don’t wish to proceed. He also said the current queue process takes too much time and doesn’t lend enough certainty to interconnection customers due to the volume of restudies.
“What we’re going to do is restructure the restudies and minimize the number of restudies allowed,” he said.
The new rules would eliminate restudies after interconnection customers execute a permanent generator interconnection agreement.
The new rules set new deadlines for receiving refunds of milestone payments.
Godbole said interconnection customers proposing a project will receive a detailed study from MISO in the first 110 days of the process. After reviewing the study, the requesting owner can decide whether to seek a refund of the $5,000/MW milestone paid at the queue application. Before executing a generator interconnection agreement, customers must pay two more milestones during phases that last 80 and 135 days, respectively.
No refunds will be permitted for interconnection customers that do not withdraw their projects before the third, 135-day phase begins.
Godbole encouraged stakeholders to view the proposed milestone payments as “deposits.”
Several stakeholders asked for more time to consider the changes, saying at just four months the process felt “rushed.” Godbole responded that MISO has incorporated three cycles of comments thus far on the proposed changes.
Some stakeholders requested a clearer transition to the new rules.
“We’ve heard it crystal clear that stakeholders want a transition plan by the time we file with FERC,” Godbole said. He asked stakeholders to provide “actionable items” that MISO can incorporate into the plan.
MISO asked for PAC’s feedback on the changes by Nov. 25 in order to present final Tariff language to the committee on Dec. 16.
— Amanda Durish Cook
