Legalectric

Oh, I love it when this happens! North Dakota Public Service Commission, the Montana Public Service Commission, the Arkansas Public Service Commission, the Mississippi Public Service Commission,
and the Louisiana Public Service Commission are challenging MISO’s cost and benefit scheme via FERC!

To see the full docket, where everyone is intervening, THIRTY THREE intervenors so far, go here: https://elibrary.ferc.gov/eLibrary/search

You’ll get this screen, then go to the “Enter Docket Number” box, and enter docket EL25-109:

From the FERC eFile, the initial North Dakota, et al filings (Dig Ex. 3, the Patton Memo!):

• Concerned Commissions Complaint re MISO Tranche 2.1 Benefit Calculations (FINAL).pdf
• Exhibit 1 – Testimony of William Hogan.pdf
• Exhibit 2.pdf LRPT Tranche 2 – Business Case Benefit Metrics
• Exhibit 3.pdf – Potomac Economics 7/15/2024 Patton Memorandum
• Exhibit 4.pdf – Comments of ND Commission
• Exhibit 5.pdf – PJM Update on Analysis of MISO Tranche 2.1
• Exhibit 6 (Notice of Complaint) (1).pdf

The short version of the issues is pretty much what we’ve been saying at Minnesota Public Utilities Commission and Wisconsin Public Service Corporation for over a decade… not that they care.

On behalf of No CapX 2020 and Legalectric, I’ve filed this Intervention:

The Complaint is only about MISO’s “Tranche 2.1,” though it’s applicable to the last few rounds of the transmission buildout, and something I’ve been raising since the first cost/benefit MISO chart I saw way back when… We’re getting screwed via rates having to pay for all this transmission. They’re objecting in this Complaint, GOOD, but they’re also objecting for some of the wrong reasons, to the extent the focus is “it’s for renewables” so that other states can meet their quota (an inherent issue because transmission projects are claiming “it’s for renewables” and Commissions haven’t met a transmission “for renewables” project they don’t like. Let’s get “need” into the mix, carve out the “desire” v. “need” over-reach; acknowledgement of the capacity freed up by fossil shutdown; steady lower peak demand with a lot of excess capacity; and let’s get the necessary upgrades and storage that would alleviate much of “need” claim — these and more need to get into the mix.

Tranche 2.1 Details: MTEP24 Report

The MISO cost/benefit scheme is such a farce, the things they call benefits, and the way they shift costs away from the benefactors, it’s infuriating, and I’m thrilled to see these Commissions standing up. I do wish they go after the prior iterations retroactively, as those are just as bad.

This Complaint is long overdue!