PAC: LRTP/JTIQ Integration Changes (20250416)

1. ICs entered applications into DPP-2023 not expecting to be allocated costs associated with JTIQ because of MISO’s then effective Tariff language.
   1. All decisions to enter applications in this cycle were made without considering JTIQ.
   2. This is akin to retroactive ratemaking because DPP-2023 customers will potentially be assessed a JTIQ Generation Charge even though that was not part of the Tariff when they entered DPP-2023.
2. MISO’s response that ICs can still drop out of DPP-2023 because it hasn’t kicked off yet is not an acceptable solution. GI customers have already invested significant time and costs based upon a different MISO Tariff construct that existed at the time of DPP-2023 application. For example:
   1. There have already been significant investments in obtaining site control and procurement of long lead time items.
   2. There is now a queue cap, and the East (ITC) cap has already been reached. By the time FERC acts on MISO’s JTIQ proposal it is likely other regions will have reached their cap.
   3. If MISO's ERAS proposal is accepted, ICs will face greater cost and network upgrade uncertainty.
3. ICs that entered applications into DPP-2023 as ERIS and that are along the MISO-SPP seam will be treated differently than ERIS customers elsewhere (i.e., they will be allocated the same network upgrade costs as NRIS customers) thus defeating the purpose of ERIS.
4. JTIQ was originally supposed to be implemented across the MISO and SPP 2024 study cycles.  SPP has already begun DISIS-2023 without considering JTIQ.  If MISO integrates JTIQ into DPP-2023, it would be discriminatory towards MISO ICs.
5. Adding JTIQ Screening to the DPP-2023 cycle introduces financial risks to the ICs which were not accounted for. Sudden changes in Tariff/GIP after DPP window closing should be prohibited to maintain fairness for all stakeholders/participants.
6. Submitting a filing to FERC to allow MISO to integrate JTIQ into DPP-2023 will further delay the kickoff of DPP 2023, which has already been significantly delayed. MISO should not deliberately delay the July 7th kickoff of DPP 2023 in hopes that FERC will accept JTIQ integration.

1. Is MISO planning on providing a screening study to show cost implications on a project due to JTIQ network upgrades? Will MISO provide that assessment as part of the screening study for the DPP 2023 cycle prior to kick off so that ICs know if they are impacting any JTIQ network upgrades?

Thank you for the request for feedback and that opportunity,

Regarding the inclusion of expected transmission changes/upgrades in transmission system models, in this case DPP2023, EDF supports, prefers, and expects that transmission models should be as up to date as reasonably possible upon the start of a process or in this case the study period. It is inefficient to use obsolete or incomplete models to test effects of possible future changes. EDF would hope and expect that MISO would do its best to use as good as practical models in its various processes, it is appreciated that they do so. This being the case, EDF supports and appreciates MISO's efforts to do that for the generation interconnection process for DPP2023 by offering/making edits to BPM-015 to enable integration of expected transmission upgrades and additions into the base/bench (pre-project) case.

Temujin Roach, EDF Senior Director - Transmission Policy

National Grid Renewables (NG Renewables) has major concerns with integration of the Joint Targeted Interconnection Queue (JTIQ) portfolio into the 2023 DPP cycle. The current approved cost allocation for JTIQ assigns 100% of costs to generation and 0% to load, despite load deriving significant benefit from JTIQ lines. This lopsided cost allocation was originally approved because of the provision of grants by the Department of Energy (DOE) Grid Resilience and Innovation Partnerships (GRIP) Program to fund almost half the JTIQ portfolio. However, the certainty of this funding has come into question under the current presidential administration.  Thus, it would be inappropriate to accelerate JTIQ until MISO can confidently assert that the funds provided by DOE for the JTIQ lines will not be rescinded. Without this assertion, generators could inappropriately be allocated more than double the costs that were originally estimated.  Furthermore, the In-Service Date (ISD) of the JTIQ projects is not certain. Without secure funding mechanisms, construction of the JTIQ lines would likely be delayed or halted. If MISO includes the JTIQ lines in the 2023 DPP cycle, many generators will be contingent on those facilities for many years, in some cases potentially limiting their interconnection rights until those lines are built. NG Renewables is highly concerned with the logistical challenges- both in cost allocation and in construction timelines- that would occur if grant funding for JTIQ was withdrawn. Therefore, NG Renewables opposes pre-maturely integrating this portfolio into DPP 2023. 

The MISO Transmission Owners (Owners) are supportive of the proposed edits to BPM-015 to enable integration of LRTP Tranche 2.1 into the DPP 2023 cycle and the proposed integration of JTIQ into the DPP 2023 cycle as presented at the April 16^th PAC meeting.

TO: MISO

FROM: THE ENTERGY OPERATING COMPANIES

SUBJECT: PAC: LRTP/JTIQ INTEGRATION CHANGES (20250416)

DATE: APRIL 29, 202

The Entergy Operating Companies (Entergy) appreciate the opportunity to provide feedback on MISO’s proposals to revise BPM-015 for LRTP Tranche 2.1 integration and to seek FERC approval to modify Attachment X for JTIQ integration into the DPP 2023 cycle. While the proposals appear generally reasonable, Entergy offers the following comments and considerations for MISO’s evaluation.

LRTP Tranche 2.1 Integration – BPM-015 Revisions

Entergy generally supports the proposed revisions to BPM-015 to allow inclusion of LRTP Tranche 2.1 projects in the DPP 2023 bench case. This adjustment aligns the study base case with more current transmission planning assumptions and reduces the likelihood of identifying redundant or unnecessary network upgrades. However, Entergy emphasizes the following considerations:

• Risk of Premature Inclusion: There is inherent risk in basing interconnection upgrades on projects not yet in service. If LRTP projects are later cancelled or modified through the Variance Analysis process, affected interconnection customers may face delayed or uncertain service, and interconnection costs may be unreasonably shifted from interconnection customers to load as noted below.
• Contingency and Cost-shifting Concerns: There are also concerns in cases where an MTEP project is listed as a Contingent Facility in a GIA, and is later terminated, that the TO must find an alternative transmission solution to mitigate the constraint that the MTEP project was mitigating in the interconnection study results. Because the costs of the replacement project would be borne by the load in the transmission pricing zone in which the transmission project is located, not by the interconnection customer, the result would be an unreasonable cost shift.
• Dependency Identification and Conditional Service: MISO should conduct a dependency analysis identifying which interconnection customers’ ERIS/NRIS is contingent on which LRTP projects. This would ensure consistency with current conditional service practices and help mitigate interim congestion risks.
• Equal Treatment in Study Process: MISO should ensure that LRTP projects are subject to the same contingency and dependency review as other future upgrades, possibly through the A10 process or an equivalent evaluation.

JTIQ Integration into DPP 2023 – Tariff Revisions

Entergy does not object to MISO pursuing a Section 205 filing to revise Attachment X of the tariff to permit inclusion of the JTIQ portfolio in DPP 2023. The feedback below addresses implementation considerations for how JTIQ project assumptions are handled in the DPP base case and how MISO should ensure proper treatment of dependencies between interconnection customers and JTIQ facilities.

• Clarification of JTIQ Dependencies: MISO should clarify how dependencies on JTIQ projects will be tracked and evaluated during the interconnection study process. For example, if a generator is assumed deliverable based on the presence of a JTIQ project in the base case, it should be clear how that dependency is documented and how conditional service is applied in cases where the JTIQ facility is delayed or incomplete.

Conclusion

Entergy supports MISO’s efforts to update its processes to reflect recently approved transmission portfolios. However, these changes must be accompanied by robust implementation practices that ensure transparency, maintain system reliability, and minimize cost exposure and/or avoid unreasonable cost shifts due to potential JTIQ or LRTP project modifications or cancellations. Entergy encourages MISO to engage further with stakeholders on implementation specifics and perform detailed analysis on generator contingencies associated with this change to including LRTP and JTIQ portfolios for the 2023 DPP Cycle.

Pine Gate Renewables appreciates the opportunity to provide feedback on MISO’s proposed LRTP/JTIQ Integration Changes presented at the April 16 PAC meeting.  We understand that planning updates have occurred since the DPP 2023 requests were initially submitted, and that it is prudent for MISO to incorporate these changes before DPP 2023 studies begin.  As MISO continues to clear the interconnection backlog and shorten study timelines, we hope that such policy changes to active interconnection requests will rarely occur.

Since DPP 2023 Phase 1 study begins in three months, additional information on the JTIQ per-MW generator charge is warranted.  Is MISO going to use the JTIQ portfolio cost filed in the FERC proceeding (~$1.7 billion) to calculate the final per-MW JTIQ charge for the DPP 2023 cycle?  If not, can MISO confirm when it plans to update the cost of the upgrades?  It will be helpful for customers to have upgrade cost estimates prior to the start of Phase 1, or at the latest, when customers are notified that they are likely assigned JTIQ upgrades before the start of Decision Point 1.  Additionally, prior to posting the pre-screening results, MISO should organize an educational presentation or workshop to refresh customers on how the generator charge is calculated.  Understanding the certainty around the assumptions MISO and SPP use in the calculation will be critical in informing customers what the estimate will be and how it may change over time.

Pine Gate shares the concern with other stakeholders that DPP 2023 cycle projects were not planned to participate in JTIQ, and that such a significant shift in assumptions can change the outlook of these projects.  To provide customers with time to assess their projects under this new paradigm, we recommend that MISO provides the screening analysis with JTIQ upgrades more than 15 calendar days prior to the kickoff of Phase 1.  Additional time will allow customers to run the appropriate internal analysis and allow ready projects to move forward.

We also share the concern that any cost increases from a loss in GRIP funding would be automatically passed along to interconnection customers.  As outlined in the JOA and Tariff, the current cost allocation only applies to upgrades that receive GRIP funding. Can MISO confirm that any loss in GRIP funding would trigger a new stakeholder review for an appropriate cost allocation?

Lastly, we believe that JTIQ integration into DPP 2023 and JTIQ integration into ERAS are two different topics – additionally, ERAS is still contingent on FERC approval. Therefore, MISO should either submit two different filings or the filing should be made severable.

Cordelio appreciates the opportunity to provide feedback on PAC: LRTP/JTIQ Integration Changes as presented at the PAC on April 16.

Cordelio opposes integrating JTIQ into DPP 2023 cycle. When DPP 2023 Interconnection Customers submitted projects, it was months before FERC approved JTIQ. At that time, DPP 2023 was planned to start in July 2024, again months before FERC approved JTIQ. Interconnection Customers acted reasonably when assuming DPP 2023 would not have JTIQ integrated. At this point in the process, it is unreasonable to increase risks and costs being imposed on DPP 2023 by adding JTIQ projects.

Cordelio supports integrating JTIQ into cycles following DPP 2023, so that Interconnection Customers are given the opportunity to consider JTIQ impacts when they submit projects.

Thank you for the opportunity to provide feedback regarding MISO’s proposal to integrate LRTP Tranche 2.1 and JTIQ projects into the DPP 2023 cycle. The Environmental Sector supports inclusion of LRTP Tranche 2.1 but opposes the inclusion of JTIQ projects into the 2023 DPP cycle.

While we appreciate MISO’s position that both portfolios of projects have been approved by the MISO Board of Directors and, therefore, should be included as mitigating projects in the upcoming DPP cycle, the critical distinction is that including JTIQ projects in the 2023 DPP cycle will likely create a material harm for DPP 2023 cycle interconnection customers through the application of JTIQ charges to projects that entered the 2023 cycle with an expectation that they would not be exposed to such charges. MISO’s proposal to include LRTP Tranche 2.2 in the 2023 DPP cycle does not carry such risk and, in fact, will likely lower interconnection upgrade costs for interconnection customers in that cycle. We agree with feedback received at the IPWG from Alliant Energy and the Transmission Owners to that effect. 

While we don’t oppose JTIQ charges in principle, including such a risk in the 2023 DPP cycle ex post facto changes the rules of the game – and the expectations for financial risk – of customers who entered the 2023 DPP cycle expecting potential JTIQ charges to not apply. This is a poor precedent for MISO to set, will likely lead to unexpected charges for customers, and could lead to a significant number of projects dropping out of the 2023 cycle – an occurrence that MISO itself has identified as an issue it seeks to avoid. And this is at the heart of why we support incorporating LRTP Tranche 2.1 but not JTIQ in the 2023 DPP cycle: while both change the analysis conducted by interconnecting parties prior to this late change, the former can be considered neutral or net beneficial, while the latter introduces material financial harm to a substantial number of interconnecting customers. Looking at ex post facto principles generally, such changes are generally accepted when they result in no material harm, but their acceptance falls under much greater scrutiny and is often rejected when a material harm is the result.

Unfortunately, provisions to allow a penalty-free withdrawal for projects seeking to avoid JTIQ charges is a suboptimal remedy because having to withdraw and reenter the queue at a later cycle is, itself, a material harm and may cause some projects to lose their financing. And we are unconvinced that MISO’s process for penalty-free withdrawal is even workable because it does not provide sufficient time for interconnection customers to fully evaluate their risks of remaining in that cycle or withdrawing.  

Southern Renewable Energy Association (SREA) appreciates the opportunity to provide feedback on MISO’s proposal to integrate LRTP Tranche 2.1 and the JTIQ portfolio of projects in recent DPP Cycles. The presentation offered by MISO provided details on the approach to integration for JTIQ through a Tariff Amendment to be filed with FERC in the very near term for a targeted implementation before kick off of DPP2023 in July ‘25. In a separate presentation MISO outlined integration of LRTP Tranche 2.1 lines, which detailed their incorporation into DPP2022 and 2023 models to be utilized for mitigations in these cluster study cycles. We are supportive of the latter proposal, but have concerns about the incorporation of JTIQ screening in DPP23, given that discussions about cost allocation, screening process, $/MW charges for IC’s and the status of federal grant funding for the majority of cost recovery for JTIQ were still under consideration when IC’s submitted projects to that cycle.

While at face value there is benefit to JTIQ integration we have an overarching concern that the benefits that developers understood while entering the queue will fall short of the commensurate costs assigned to them. Currently, the language in MISO’s tariff as it relates to JTIQ assigns 100% of costs to generators, which could further complicate cost recovery if DOE funding were not to materialize. This would raise costs even further for DPP2023 participants that agreed to one set of assumptions around cost allocation but would be presented with a potentially much more concerning picture.

However, we do recognize that benefits of JTIQ may in fact be a net, and maybe even a significant net benefit for IC’s. For that reason we believe that IC’s should be given more than the allotted ten business days outlined in MISO’s presentation to carry out their analysis at DP1. Twenty business days would be a meaningful improvement to the current proposal to ensure IC’s that they can confidently move ahead with a project, or withdraw from the queue without penalty. We also urge MISO to provide more than fifteen calendar days between the Screening Analysis and Phase 1 kick-off. Twenty calendar days would be more appropriate for IC’s to make the decision to participate in the queue. Ultimately, this extra time ensures that IC’s in the queue have a higher level of confidence in committing to a cycle and are less likely to drop out later - causing restudies and delays.

Additionally on the topic of expected costs and benefits related to JTIQ, can MISO confirm if the cycle’s JTIQ charge will be based on the portfolio’s cost estimates shared in the FERC filing ($1.7 billion)? If MISO plans on updating the JTIQ charge to reflect more recent costs, having a cost refresh would be very helpful for developers in making decisions at DP1. The tariff says that an estimated pre-MW charge will be provided to customers before the beginning of DP1. Ideally MISO would do a JTIQ cost refresh so IC’s have an updated expected rate, if not before Phase 1 starts, then prior to DP1 as part of the notification.  

On a separate topic, we do not think that edits to incorporate ERAS into JTIQ are appropriate in this filing. ERAS is a separate topic and should either be in a separate filing or severable.

SREA and developers are always eager to engage in providing feedback into the MISO stakeholder process in the hopes that MISO is receptive to policy that benefits market participants dependent on access to affordable and reliable resources provided by our membership.

Steelhead Americas is against inclusion of the JTIQ Portfolio in the DPP-2023 Cycle. The additional cost to be borne by generators is a major deviation from the known assumptions when DPP-2023 Cycle generators submitted their applications. We continue to maintain that the benefits for many generators distant from the portfolio will not outweigh the costs, so adding these unexpected costs will throw off the business case for numerous generators in this cycle. 

Adding to the uncertainty, we have not seen any preliminary JTIQ cost adders. It is critical to receive these numbers with sufficient time to evaluate applicable queue positions prior to the start of that study and before the end of the penalty free withdrawal window.

Integration of Long Range Transmission Planning Tranche 2.1 (LRTP 2.1) and Joint Targeted Interconnection Queue (JTIQ) into DPP 2023 Cycle
April 29, 2025

Clean Grid Alliance appreciates the opportunity to comment on the proposed integration of JTIQ and LRTP Tranche 2.1 into the DPP 2023 Cycle

While CGA generally supports the proposed BPM-015 edits to for timing of MTEP MVP/LRTP project inclusion into DPP models, we take a neutral stance on integration of LRTP 2.1 into DPP 2023. We fully support the BPM 15 change for application to future DPP cycles, as interconnection customers will be aware of the BPM inclusion provision in advance. 

In regard to JTIQ, Clean Grid Alliance is strongly opposed to JTIQ inclusion in the DPP 2023 cycle for the following reasons: 

• Mid-Cycle Rule Changes: Including JTIQ into DPP 2023 alters the rules after developers made commercial decisions to enter the queue based on existing tariff language. This introduces significant uncertainty and cost increases to projects which undermines the predictability necessary for project financing and development. DPP 2023 projects entered the queue having specifically modeled the transmission system without the unpredictable cost exposure JTIQ creates, and do not want the process changed at this point. If it is a matter of either including both or omitting both, then we request that MISO omit both given the significant negative impact JTIQ will have on projects. 

• Cost Uncertainty to the JTIQ Expanded Scope Study: Developers oppose JTIQ due to its additive costs alongside the JTIQ Expanded Scope Study (ESS), which is basically the same Affected System Study as prior to the JTIQ portfolio, introducing the potential for “lumpy” upgrades to be assigned to projects, all the way up to 345KV level. MISO had claimed early in the JTIQ process that JTIQ would replace the AFS, but later added in the ESS, which although the name is different, the function is the same. Lower DFAX thresholds on the ESS over the old AFS significantly increase cost exposure for projects and add uncertainty since the SPP system was bult to a 20% DFAX while MISO generators will be held to a 10% DFAX standard on the SPP system, requiring them to build transmission in SPP at a higher standard. 
  
  
• Cost Uncertainty due Un-Capped Costs of JTIQ lines: JTIQ does not have a cost cap for the lines – prices can increase significantly and the only oversight of cost increases (10% cost allocation to states would have afforded some oversight) was removed very late in the process, contrary to representations MISO had made earlier in the JTIQ process, and without consideration of the impact and consequences on cost increases. 
  
  
• Unpredictable Risk Due to Lack of Cost Causation: JTIQ cost allocation is contrary to “but for” principles as the 5% DFAX applies to power flows from new projects on the new lines, and has nothing do with a project actually needing JTIQ or not or having any constraints—projects will get pulled into JTIQ costs simply because of power flows in the path of least resistance and projects could far away from the seams that would have never needed JTIQ lines can be allocated JTIQ costs. It is also unknown if the JTIQ portfolio actually solves the right constraints today, as the system had changed significantly by the time it was filed and even more so today. Without cost causation, generators could be paying for lines that don’t even benefit them at all. 
  
  
• Withdrawal Window: The penalty-free withdrawal window (before the DPP 2023 study kickoff) is insufficient for developers to assess JTIQ’s cost impacts. Screening studies, which provide initial thermal overloads and cost estimates, often lack detailed information on specific upgrades (e.g., 345 kV lines), which typically emerge later in Phase 1 and Phase 2 studies. This lack of early clarity prevents developers from making informed decisions prior to the point where they can withdraw without financial penalties. Furthermore, it’s not clear if MISO will actually perform the Extended System Study that can assign full line upgrades to projects, prior to Study Kick off for interconnection customers to see the full cost of JITQ upgrades.
  
  
• DOE Funding Stability: A significant portion of JTIQ’s costs rely on Department of Energy (DOE) grid funding, which faces risks of reduction or reallocation, as seen in recent federal funding reviews. If DOE funding is reduced or removed, developers could face significantly higher costs, potentially doubling their financial exposure and/or causing projects to withdraw that would not otherwise have needed to. While we do not support JTIQ integration into DPP 2023 for the reasons noted above, we are especially opposed to it occurring without language causing load to be responsible for the DOE funds, should those funds not show up (or another mechanism that ensures the anticipated DOE funding is not cost allocated to generators). 

Clean Grid Alliance is strongly against JTIQ inclusion in the DPP 2023 cycle and requests that MISO begin the process of Tariff and JOA changes to JTIQ to address the issues noted above that are responsible for high cost variability when projects are subjected to JTIQ. Additionally, we refer MISO to our JTIQ comments from December 2023 where many of these concerns were raised prior to also being raised in protests to the filing, including the lack of cost predictability due to inclusion of the Extended System Study which introduces “lumpy” transmission upgrades into the JTIQ process, similar to the earlier MISO-SPP Affected System Study, but is now "additional" to the uncapped JTIQ portfolio charges. JTIQ transmission lines lack a cost containment mechanism that other 345kV lines assigned to generators would automatically have as a result of state oversight for the 10% direct cost to load, while the entire portfolio cost is pro-rata allocated to generator interconnection projects based on a 5% power flow on any single JTIQ line, rather than due to a generation project actually causing or contributing to any constraint, which also unexpectedly increases and cost and risk to DPP 2023 projects that had not been modeled, planned for, or anticipated prior to DPP 2023 entry. 

https://www.misoenergy.org/engage/stakeholder-feedback/2023/pac-jtiq-updated-approach-20231115/

Sincerely, 

Rhonda Peters, Ph.D. Technical Consultant 

Tyler Bergman, Clean Grid Alliance Senior Manager of Transmission and Markets 

PAC: LRTP/JTIQ Integration Changes
MISO Dashboard ID#: PAC-20250416
Feedback Due: April 29, 2025

At the April 16, 2025 Planning Advisory Committee (PAC) meeting, MISO proposed edits to BPM-015 to enable integration of Long-Range Transmission Planning Tranche 2.1 (LRTP 2.1) into the Definitive Planning Phase (DPP) 2023 Cycle.  NextEra Energy Resources (NextEra) appreciates the opportunity to provide the following responsive feedback on this important topic.

NextEra does not support the proposed changes to BPM-015 that would integrate the transmission investments identified in LRTP 2.1 into DPP 2023 bench case models. Such a move is a significant departure from the existing business practices that developers have relied on to develop and implement multi-year investment strategies. MISO has not provided any analysis supporting this proposal or the benefits it could provide, whereas the adverse commercial impact to developers is real. The window for submitting projects to DPP 2023 has long been closed, so developers have no ability to revise or add projects to that cycle commensurate with the acceleration of LRTP 2.1 into the DPP 2023 bench case. Moreover, developers currently are submitting projects into the DPP 2025 cycle, anticipating LRTP 2.1 would be integrated in that cycle. The inability to add projects to DPP 2023 and commercial implications to projects either submitted or planned to be submitted for 2025, along with the significant DPP delays across all cycles makes accelerating LRTP 2.1 commercially harmful to developers. As one stakeholder described during the April 16 PAC, this proposal is like changing the rules of the game while the game is being played. This proposal upsets commercial expectations and increases costs for customers. NextEra strongly urges MISO not to move forward with the proposed BPM amendments that would accelerate LRTP 2.1 into the DPP 2023 bench case.