Invenergy’s FERC complaint shows gaps in regional planning

A Federal Energy Regulatory Commission complaint by a transmission subsidiary of Invenergy shows barriers for merchant transmission developers.

Invenergy claims MISO erred by not including its Grain Belt Express in its Long Range Transmission Plan, and MISO replied that without a signed interconnection agreement for the generators injecting energy, MISO could not include the line per its tariff. Depending on which way FERC rules, the outcome could impact the business prospects of merchant transmission developers.

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Invenergy is complaining that the Grain Belt Express (GBX) transmission line should be included in Long Range Transmission Plan (LRTP)

The GBX High Voltage Direct Current (HVDC) transmission line connects southwest Kansas in Southwest Power Pool (SPP) to the northern Missouri of Midcontinent Independent System Operator (MISO) market. As of October, some Missouri farmers are unhappy with the GBX line.

In requesting a “fast-track” treatment to resolve its August complaint at FERC, Invenergy stated, “MISO’s tariff does not require merchant transmission to have an interconnection agreement or be part of a state or utility IRP to be considered in the MTEP.” To justify its position, Invenergy says MISO is inconsistent in how it applies its generator interconnection procedures.

Invenergy points to MISO’s study assumptions for generator deliverability, where it turns on generators with signed Interconnection Agreements (IA) from the current study cycle and generators in Phase 3 of the Definitive Planning Phase (DPP) without signed IA of the future study cycles. But FERC could reject this argument because Invenergy admits that MISO does not extend this treatment of Phase 3 projects to MTEP.

MISO answers that GBX does not have a signed interconnection agreement

In addition to existing generation, future generators with signed interconnection agreements are modeled in transmission planning models at MISO. Similarly, for proposed transmission projects, once the MISO Board approves a portfolio of transmission projects in an annual MISO Transmission Expansion Plan (MTEP) cycle, they become “Appendix A” projects and are included in planning models.

MISO rebuts that generators at the sending and receiving end of the HVDC line need signed IAs. Or GBX should be part of a state Integrated Resource Plan (IRP) filed by one of the Load Serving Entities to meet their resource adequacy obligations. Since GBX is neither, MISO is not including GBX in its planning models to study LRTP.

Transmission Owners (TOs) are on the MISO side of the argument and ask FERC to reject Invenergy’s complaint. MISO TOs assert that Invenergy asks for “special treatment” because GBX is “advanced stage merchant transmission.” As part of the Merchant HVDC Transmission Connection Procedures (Attachment GGG), Invenergy must have a signed interconnection agreement for the GBX line. Only then should MISO include GBX in LRTP assert MISO TOs.

Only fellow merchant developer SOO Green HVDC comes to the defense of Invenergy

SOO Green has been in the shoes of Invenergy because of its similar experience at PJM. To my knowledge, FERC has not yet acted on the SOO Green complaint.

SOO Green’s support of Invenergy points to similarities, such as both projects enable a large amount of energy (Invenergy enables 5,000 MW whereas SOO Green enables 2,100 MW). Hence excluding these merchant transmission projects in MISO’s LRTP leads to inaccurate results and reduced “reliability, resilience, market and public policy benefits.” MISO seems to favor its Transmission Owners by ignoring merchant developers’ concerns.

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At stake is the future of Merchant High Voltage Direct Current (MHVDC) transmission projects

Invenergy’s complaint about MISO’s transmission planning processes concerning Merchant HVDC projects highlights the gap in regional planning. The gap is a limited role for Independent Transmission Companies (ITCs). For instance, first, MISO and other Regional Transmission Organizations (RTOs) are including their Transmission Owning member local planning criteria-driven transmission projects in their expansion plans under the justification that these are reliability-based projects, and only TOs can build them because FERC does not mandate competition for these lower voltage projects. Second, RTOs are putting together a large portfolio of transmission projects for implementing policy needs where there is competition but ensuring a limited role for ITCs, as demonstrated by MISO’s LRTP Tranche 1, where only 20% is bid for competition.

Merchant HVDC projects can fill this gap if FERC allows them. If FERC is serious about incentivizing transmission build-out for integrating renewables and preventing blackouts, there must be room for both the incumbent TOs and merchant transmission developers.


It remains to be seen if FERC acts on this August 2022 Invenergy complaint. At the end of September, Invenergy said GBX was included in Ameren’s Integrated Resource Plan (IRP), and MISO responded, “Invenergy’s new IRP claims are baseless.”

If FERC rules in favor of Invenergy and tasks MISO to include GBX as sensitivity in LRTP Tranche 1 or 2, that could be a big win for merchant HVDC players like Invenergy. If FERC sides with MISO and rejects Invenergy’s complaint, then, Invenergy must wait until it executes interconnection agreements for all the generators injecting energy into the Grain Belt Express line.

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Author: Rao Konidena