Americans for a Clean Energy Grid Intervenes in FERC Proceeding to Clarify Transmission Planning Authority

Strategic Insights -

Americans for a Clean Energy Grid (ACEG) has submitted comments to the Federal Energy Regulatory Commission (FERC) in support of a petition filed by the Midcontinent Independent System Operator, Inc. (MISO). ACEG is a non-profit public interest advocacy coalition focused on expanding, integrating, and modernizing the high-capacity transmission grid in the United States. In their comments, ACEG argues that MISO's Open Access Transmission, Energy and Operating Reserve Markets Tariff does not grant MISO's Independent Market Monitor (IMM) the authority to unilaterally undertake transmission planning and monitoring activities.

Key Takeaways:

  • ACEG, a coalition of multi-state utilities, transmission owners, and other stakeholders, has intervened in the FERC proceeding to clarify transmission planning authority.
  • ACEG argues that MISO's Tariff does not provide the IMM with the authority to undertake transmission planning and monitoring activities.
  • Transmission planning is critical to meeting the identified needs of the MISO region, which includes expanding its regional transmission to meet moderate load growth by 2035.
  • The IMM's responsibilities are limited to implementing the IMM Plan, reviewing market power, and performing tasks related to market design and monitoring.
  • The Tariff contemplates the recovery of costs for services by the IMM in a separate section from the provisions establishing recovery for transmission planning charges.
  • ACEG respectfully requests that FERC grant MISO's petition and find that MISO's Tariff does not authorize the IMM to unilaterally engage in transmission planning and monitoring activities.

Statistics:

  • The Midwest region needs to more than double its regional transmission to meet moderate load growth by 2035. (Source: U.S. Department of Energy's triennial state-of-the-grid report)
  • MISO region has a significant deficiency in interregional transfer capability, with a maximum of 58 hours and 5,715 MW shortages. (Source: NERC's Interregional Transfer Capability Study)
  • Transmission planning and monitoring activities in MISO should proceed efficiently in accordance with the tariff to meet identified needs. (Source: MISO's Petition)
  • The IMM's tasks are limited to implementing the IMM Plan, reviewing market power, and performing tasks related to market design and monitoring. (Source: MISO's Tariff)

Sources:

  • Americans for a Clean Energy Grid. (2025, May 7). Petition for Declaratory Order of Midcontinent Independent System Operator, Inc. (Docket No. EL25-80-000)
  • Midcontinent Independent System Operator, Inc. (2025, May 7). Petition for Declaratory Order.
  • U.S. Department of Energy. (2023, October). National Transmission Needs Study.
  • N. Am. Elec. Reliability Corp. (2024, November). Interregional Transfer Capability Study.
  • Brooks, A., Gramlich, R., & Silverstein, A. (2025, June). The Resource Adequacy Value of Interregional Transmission.
  • Zimmerman, Z., et al. (2025, June). Large-Scale Transmission Deployment Saves Consumers Money.