Even though the Midcontinent Independent System Operator CEO’s testimony to Congress in October 2019 states: “MISO is fuel and policy-neutral,” studies by the grid operator favor transmission owners, not distributed energy resource providers.

The federal regulator envisioned a neutral umpire role for grid operators. To implement the Federal Energy Regulatory Commissions Order 2222 on the aggregation of distributed energy resources, MISO must conduct studies to estimate market potential.

Unlike MISO’s transmission studies that result in board approval of transmission portfolios, MISO’s current assessments for demand and energy projections do not show which transmission was avoided, nor do they drive market improvements for flexible loads. MISO must do more for flexible loads.

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MISO favors transmission and natural gas over distributed energy resources

Unless regulators in MISO states and federal regulators remind MISO about its independent system operator responsibilities of staying neutral, MISO thinks only natural gas and transmission will solve its capacity deficiencies.

It is tough for someone who does not follow MISO closely to connect the dots and ring alarm bells. Take MISO’s Regional Resource Assessment (RRA), for example. In the 2022 RRA, MISO clearly states: “Hybrid and battery units may help to reduce the evening peak net load by shifting energy demand to off-peak hours.” But MISO has not taken any steps to advertise that behind-the-meter energy storage can participate in MISO markets due to FERC Order 841. Instead, MISO is advocating for natural gas as a dispatchable capacity.

In addition to RRA, MISO has started an “attributes” discussion with stakeholders. A close examination of these six attributes leads one to believe that only natural gas fits MISO’s definition. E&E News quotes a MISO Executive who said at a Missouri Public Service Commission meeting: “Today, the only thing that we’re aware of that would provide those attributes are gas units.” Does that mean only natural gas can provide availability, fuel assurance, ramp-up capability, voltage stability, rapid start-up, and long-duration energy at high output? Most energy storage and distributed energy resource providers would beg to differ.

As the three examples below indicate, MISO is turning into a consulting shop for transmission owners under the umbrella of an “independent” system operator when acting like a “transmission” system operator. FERC staff must take notice and watch for this behavior from MISO and other ISOs and do something about it before more harm is done to the distributed energy resource and flexible load providers. The specific concern is that MISO has not studied the costs and benefits of integrating aggregations of distributed energy resources to implement FERC Order 2222.

Manitoba Hydro Wind Synergy Study led to Great Northern Transmission Line for Minnesota Power

The Great Northern Transmission Line (GNTL) is a perfect example to show that MISO transmission planning favors Transmission Owners. Minnesota Power, a transmission owner in Minnesota, put in a long-term transmission service request (TSR) at MISO around or right after MISO Board approved the MVP portfolio in December 2011. The 500 kV GNTL energized in June 2020 brings hydropower from a Canadian utility, Manitoba Hydro, to the MISO market.

To study Minnesota Power’s long-term TSR, MISO initiated a Manitoba Hydro Wind Synergy Study. This study found that it is economical for the MISO market to make the uni-directional External Asynchronous Resource (EAR) bi-directional and justified Minnesota Power’s transmission investment. Before this 2015 market improvement, which FERC approved, MISO was importing energy from Manitoba Hydro, and now, MISO can also export.

Break the System study – the 100% Renewable “RIIA” study

MISO TOs get what they want from MISO, even though MISO must take diverse stakeholder opinions in monthly stakeholder committee meetings. It is hard for an outsider to understand the transmission studies sequence RGOS-MVP-RTOS-RIIA-LRTP from MISO.

Before the MISO board approved the MVP portfolio in 2011, MISO ran a Regional Generation Outlet Study (RGOS). Renewable energy advocates and MISO states remember filling out the RGOS survey because MISO asked state and state commission staff about their Renewable Portfolio Standard (RPS) requirements to design a transmission portfolio. So, RGOS led to the MVP portfolio.

MISO tried to follow up on RGOS’s success with the Regional Transmission Outlet Study (RTOS). But that was a failure because the perception by the regulators in states like Arkansas, Louisiana, and Mississippi was that MISO south would have to pay for the north’s transmission costs.

MISO north region’s influence is felt across MISO transmission planning because the north transmission utilities, with their CAPX 2020 plan, drove MISO into action with the Multi Value Project.

MISO was feeling pressure in the TO community to develop a transmission portfolio in the 8 years since MVP approval. So, MISO started 100% renewable RIIA stakeholder workshops in November 2019 and ended with a report in February 2021.

And as soon as MISO wrapped up the RIIA report, MISO started the stakeholder workshops for Long Range Transmission Planning (LRTP) in April 2021.

So, before the pandemic started in the spring of 2020, MISO tried replicating its 2011 success with an MVP portfolio. Enter LRTP.

RIIA led to Long Range Transmission Planning (LRTP)

LRTP is MVP 2.0.

In July 2022, MISO Board approved the LRTP Tranche 1 Portfolio. Why Tranche 1? Why not the entire region? Because MISO asked FERC and FERC granted a transmission cost proposal that allocates costs for the MISO north region separately from MISO south region.

MISO north TOs were unsuccessful in socializing transmission costs across the south region. How many tranches are there? MISO said there are 4 tranches of transmission portfolios.