Regulators of MISO states are mulling whether they should work together to offer up an entirely new cost allocation for the RTO’s long-range transmission projects.
The Organization of MISO States’ leadership said it will hold meetings on whether regulatory staff think FERC’s Order 1920 should open the door for a new cost-allocation design for MISO’s regional transmission projects. OMS members contemplated the idea at an April 28 meeting of the OMS Cost Allocation Principles Committee (CAPCom), with MISO South regulators appearing more open to shedding MISO’s current, 100% postage stamp allocation to load used for long-range transmission projects.
Order 1920 directs RTOs to involve states when developing or amending a long-term regional transmission cost allocation. It gives states the go-ahead to meet independently to negotiate and devise cost-allocation methods to offer to FERC in place of RTOs’ methods.
Regulators of some MISO states at the meeting said they’re ready to pursue something different, while others said the postage stamp status quo remains the best answer.
Minnesota Public Utilities Commissioner Joe Sullivan said OMS extensively examined MISO’s cost allocation when it began planning long-range transmission projects. (See FERC OKs MISO’s Bifurcated Cost-allocation Tx Design.)
He said he didn’t think OMS could do better this time around. “We had a really long process that I thought was really good about ex ante cost-allocation alternatives. I think I’m on record that we didn’t find anything better,” Sullivan said.
But Louisiana Public Service Commission attorney Noel Darce said MISO South states want a new method of subregional cost allocation in MISO, “something other than the postage stamp.”
MISO South never has been the site of construction for a regionally cost-shared transmission project.
While Order 1920 dictates that project costs are allocated ex ante, or before the projects are built, states also have the option to negotiate with one another for up to six months after RTOs approve transmission projects to devise an alternative cost-allocation agreement for select portfolios.
MISO would have to file with FERC any alternative, all-encompassing cost-allocation design from states or their one-off alternative cost-allocation agreements, even if the RTO disagrees with it and files its own alongside the states’ preferred approach. MISO also must file a backstop cost-allocation method to use if state negotiations break down. FERC and federal courts ultimately would make calls on which cost-sharing plan is most appropriate.
New Orleans City Council attorney David Shaffer said OMS first should check in among members to see whether the postage-stamp allocation remains appropriate, or whether “positions have changed.” He said OMS should tackle that first before devising the potential state agreement process or assisting MISO with creating a voluntary funding process for projects that may not meet the RTO’s benefit-cost ratio threshold.
Under Order 1920, MISO also must create a voluntary funding rule set that allows state entities and transmission interconnection customers the option to voluntarily fund some or all of the costs of proposed projects.
Shaffer said it’s worth checking whether the states still believe the current approach is relevant and see “if there could be consensus on an alternative.”
“I think we probably should address them individually,” Shaffer said of Order 1920’s to-do list.
“I think the question for us is: Do we want to take run at something different?” said Michigan Public Service Commission Chair Dan Scripps, also chair of OMS’s CAPCom.
OMS said it will conduct an internal poll among regulators to gauge interest in designing a new cost allocation to take to MISO, at the suggestion of Mikhaila Calice, a staffer at the Public Service Commission of Wisconsin.
Scripps said OMS likely will take advantage of MISO Board Week in Minneapolis in June to meet face to face and discuss allocation options versus MISO’s status quo.
MISO Sticks with Postage Stamp
Regulators asked if MISO is open to considering a new method of cost allocation.
Jeremiah Doner said based on MISO’s assessment of Order 1920, it believes its current, postage-stamp allocation is fitting.
Doner said MISO is “largely going to be leveraging and developing” compliance through its long-range transmission planning and that it plans to tell FERC the “story” of its planning philosophy.
MISO “would point to the entirety” of the current structure used in its long-range planning in its compliance, including its approved cost allocation for long-range transmission projects, Doner said.
Doner added that OMS would embark separately on its own evaluation of current cost sharing and alternatives.
Order 1920 prescribes RTOs open a six-month engagement period with states for allocation evaluation. MISO kicked off its state engagement period by sending a letter to the Organization of MISO States. Because it was granted an extension from FERC, the RTO’s state engagement period lasts from March 11, 2025, to March 11, 2026.
The Mississippi Public Service Commission and the Louisiana Public Service Commission filed a motion to extend the state engagement period between MISO and state regulators by another six months, through Sept. 11, 2026. The two have asked other state regulators to consider joining them in the request and said that “more time is needed to allow for complex cost-allocation discussions and a meaningful, consensus-based, long-term cost-allocation method and/or state agreement process.”
MISO South representatives pushing MISO to try alternate allocation methods isn’t new.
Prior to Order 1920, MISO itself suggested using a tailored allocation plan that involved splitting costs 50-50 between the MISO South subregion and the footprint’s smaller cost-allocation zones. (See MISO Suggests Changing Cost Allocation for South Projects.)
MISO South regulators and Entergy in early 2024 countered with a proposal that would assign 90% of costs based on adjusted production cost savings and avoided reliability projects; the remaining 10% would be divvied up among new generators interconnecting in MISO South using a flow-based methodology. (See Clean Energy Orgs Push Entergy Players to Consider Broader Cost Allocation.)
Doner said he expected the regional cost allocation directive of Order 1920 would be the most interesting portion of MISO’s compliance.
MISO has until June 12, 2026, to comply with Order 1920. It plans to hold discussions on its Order 1920 compliance at upcoming Planning Advisory Committee meetings.


