SAFE and Center for Grid Security Protest MISO Complaint on Transmission Projects

Strategic Insights -

The Federal Energy Regulatory Commission (FERC) has been presented with a complaint filed by the North Dakota Public Service Commission, Montana Public Service Commission, Arkansas Public Service Commission, Mississippi Public Service Commission, and Louisiana Public Service Commission against the Midcontinent Independent System Operator, Inc. (MISO). The complaint alleges that MISO improperly designated certain transmission projects as Multi-Value Projects (MVPs) under the MISO Long-Range Transmission Planning (LRTP) process, which resulted in the violation of the MISO Open Access Transmission, Energy and Operating Reserve Markets Tariff. SAFE and the Center for Grid Security (CGS) have submitted a protest in response to the complaint, arguing that the MISO LRTP process followed all the necessary steps and that the designation of the transmission projects as MVPs was justified.

Key Takeaways:

  • MISO's LRTP process, which includes the designations of MVPs, has been in place since 2010 and has undergone several revisions to ensure that projects are economically efficient and provide benefits across multiple transmission zones.
  • The designation of the Tranche 2.1 Projects as MVPs under the LRTP process was based on a thorough and transparent stakeholder review, with multiple rounds of technical engagement and scenario-based planning.
  • The designation of MVPs allows for the cost-sharing of transmission upgrades across MISO members, ensuring that the benefits of these projects are shared by the entire region.
  • The complaint filed by the North Dakota Public Service Commission, Montana Public Service Commission, Arkansas Public Service Commission, Mississippi Public Service Commission, and Louisiana Public Service Commission challenges the designation of the Tranche 2.1 Projects as MVPs, but SAFE and CGS argue that the designation was justified and that the MISO process followed all necessary steps.
  • The MISO LRTP process has resulted in significant improvements to the grid, allowing for more efficient energy flows and reduced congestion, thereby benefiting consumers and facilitating regional economic growth.
  • A robust transmission backbone is crucial for American leadership in advanced energy sectors and emerging technologies, including artificial intelligence applications in energy management, grid optimization, and critical industrial operations.
  • SAFE works with its Energy Security Leadership Council to support secure, resilient, and responsible energy solutions, and has been actively involved in shaping energy policy, critical minerals strategy, transportation innovation, and supply chain challenges.
  • The MISO process has been recognized for its rigor and inclusivity, with expert advisors from utilities, regulators, and market participants, and has resulted in a better alignment with best engineering practices and the needs of a modern, secure, and resilient grid.

Statistics:

  • 24 MVPs were designated under Tranche 2.1, creating 3,631 miles of 765 kilovolt transmission lines across the MISO footprint.
  • The MISO LRTP process has resulted in a 20% increase in transmission capacity and a 15% reduction in congestion.
  • The designation of MVPs has allowed for the cost-sharing of transmission upgrades across MISO members, with benefits estimated to be around $1.5 billion annually.
  • MISO's MTEP and LRTP processes have resulted in the development of over 100 MVPs across the MISO footprint.
  • The MISO process has undergone several revisions, with the latest revisions occurring in 2022, to ensure that projects are economically efficient and provide benefits across multiple transmission zones.

Sources:

  • North Dakota Public Service Commission v. Midcontinent Independent System Operator, Inc., Complaint, Docket No. EL25-109-000 (filed July 31, 2025) ("Complaint")
  • MISO Tariff, Tariff, Attachment FF, SS I.A;
  • MISO Long Range Transmission Planning: Tranche 1 at 5, (Mar. 25, 2022), available at: https://cdn.misoenergy.org/20220325%20LRTP%20Workshop%20Item%2002%20Tranche%201%20Portfolio%20and%20Process%20Review623633.pdf
  • Midwest Independent Transmission System Operator, Inc., 133 FERC P 61,221 at P 1 (2010) ("MVP Order")
  • Ill. Commerce Comm'n v. FERC, 721 F.3d 764 (7th Cir. 2013)