This study is a preliminary analysis to help state decision makers determine whether to pursue more detailed analyses of IREZ corridors that are relevant to them. This report could not fully account for all the case-specific details that would affect the configuration of a transmission project. Nevertheless, if a corridor examined in this study has a high benefit-to-cost ratio based only on energy cost savings, a follow-on study focusing on that corridor might expand the economic analysis to include local factors that we were not able to address here. A guiding premise behind the IREZ analysis is that states will ultimately take the lead in deciding whether to pursue IREZ development.

This study develops a model using renewable energy zones to address the new challenges of interregional transmission planning. An interregional renewable energy zone (IREZ) is an area comprising a very high concentration of very low-cost developable renewable energy potential. An IREZ hub is a collection point on the bulk power system to which renewable energy plants built in the IREZ can connect easily. The hub anchors an IREZ corridor that consists of a dedicated high-voltage transmission path from the IREZ hub to a major load center.

We have identified and quantified several high-value IREZ corridors that affected states might consider for interregional transmission planning. Our analysis suggests that these corridors can be valuable tools for reducing carbon emissions in a manner that uses known technologies, has relatively small net impact on customers’ electricity bills, improves resource adequacy, and provides the grid with an additional measure of resilience against major disruptions related to climate change and other causes.

​Benefits could include assumptions about local tax receipts and indirect economic development effects in the IREZ state, payments to landowners for the acquisition of right-of-way (ROW) along the transmission path, net savings in energy costs for customers at the receiving end of the corridor, and enhanced resilience against extreme weather events.

Transmission lines are among the most difficult projects to receive speedy approval, Gross said, because they tend to cross multiple states and jurisdictions, each of which have their own set of requirements the developer would need to fulfill. In fact, Gross said, she already knows of one transmission line currently under development in the Midwest that would immediately benefit from state level reforms. 
The project—a lengthy transmission line called the Grain Belt Express, which would deliver electricity produced at wind and solar farms in Kansas 800 miles to Missouri and Illinois—has been delayed for more than a decade by the regulatory process and legal challenges.
“If those contiguous states had some permitting reform, you could probably get that project done,” Gross said. ​

MISO recently proposed a new 765 kV transmission line in Missouri close to where the GBX Project will connect. This is absurd given the advanced stage of GBX, disincentivizes the development of interregional merchant transmission, is contrary Commission policy, and is neither just nor reasonable transmission planning. 

MISO continues to march on blindly, act as if GBX does not exist and propose even further transmission in Missouri close to where GBX is fortifying the grid with significant network upgrades and will inject 6.3 TWh of energy annually and be online well before the new proposed 765 kV Tranche 2 Missouri transmission project would come online. This is not only unjust and unreasonable transmission practice but absurd transmission practice. It is irrational for MISO to propose even further transmission in Missouri and ignore that GBX that has obtained all its Certificates of Public Convenience and Necessity, including in Missouri, spent hundreds of millions of dollars, is committed to spend hundreds of millions more and has a TCA with MISO. 

Despite (1) over three years of discussions with MISO and its transmission owners regarding the Project; (2) GBX acquiring final state siting approvals in all 4 states as well as over 96% of the HVDC route’s right of way among other indicia of Project advancement; and (3) GBX having an effective TCA with MISO in hand, on March 4, 2024, MISO released its initial Tranche 2 Draft Portfolio which again does not consider the impact of advanced-stage merchant transmission and worse still proposes a new 765 kV transmission line that is redundant to the far more advanced GBX Project and will interconnect to the same portion of MISO’s system. Thus, MISO has not only ignored GBX in its planning, but it has intentionally leveraged the lack of clarity in its Tariff to discriminate against it. 

The Commission has long recognized that a lack of transparency and standardization of market rules impedes competition and enables the exercise of market power and undue discrimination, and that exact outcome has occurred here. The lack of a clear standard in the MISO Tariff for how advanced-stage merchant transmission will be considered in regional planning has opened up the opportunity to discriminate against merchant transmission projects, which are sorely needed to provide critical geographic diversity and interregional transfer capability during the energy transition. In the end, MISO’s behavior will not only lead to unjust and unreasonable rates, but it will rob the region of competition, access to geographically diverse resources and potentially important ties to adjacent RTOs. This should be unacceptable to the Commission, to State regulators and to ratepayers. The Commission should act now on this Complaint to protect ratepayers, prevent further delay and waste and to rectify this baffling outcome which is a direct barrier to the development of much needed interregional transmission. Therefore, Invenergy renews its request for the following relief 

Invenergy urges the Commission to issue an order as soon as possible and no later than May 15, 2024, to ensure that just and reasonable transmission practices are implemented and ratepayers are protected at the soonest possible date. 

DOE is buying something that it doesn't need and won't ever use, but will put a lot of money in the pockets of private investors who otherwise would have no buyers for their overpriced service.  Can I just say "I told you so" in advance?  This program is wasteful, illogical, and unfair.

Grain Belt notes that this area is within the geographic footprint of Southwest Power Pool, Inc. (SPP), but the generation will not be interconnected to the SPP transmission system. ​

The GBE system consists of (in part):  AC overhead transmission lines to connect the converter stations to portions of the SPP, MISO, and AECI managed electrical systems in Kansas and Missouri.  

And that...

Grain Belt contends that Phase 1 will increase resilience for the SPP, MISO, and AECI Balancing Authority Areas (BAAs) by allowing the potential of one BAA to import a large amount of power from another BAA to bolster system reliability and improve the ability of each BAA to recover after a power failure.

In the 2014 Order, the Commission directed Grain Belt “to make a filing disclosing the results of the capacity allocation process within 30 days after the close of the open solicitation process.”  Grain Belt did not submit a compliance filing during the required timeframe and, as such, has not satisfied the conditions of its initial grant of negotiated rate authority.  Grain Belt indicates that it will seek approval of the Initial TSAs in a future compliance filing.  Given the Project changes described in the instant filing and the passage of time, the Commission will conduct a de novo review of the Initial Open Solicitation and the Initial TSAs at such time as Grain Belt submits a filing providing sufficient detail to evaluate whether the capacity allocation process satisfied the Commission’s requirements.

Given that we are reviewing Grain Belt’s filing de novo, we find moot protestors’ argument that Grain Belt may not rely on the Commission’s prior grant of negotiated rate authority in the 2014 Order because Grain Belt failed to obtain section 203 approval.  Our findings here are based on Grain Belt’s current ownership structure and project design, and thus do not turn on whether prior section 203 authorization was required for either Invenergy’s acquisition of Grain Belt, or the transfer of Grain Belt’s negotiated rate authority.   ​

Grain Belt’s request for continued authority to sell transmission rights at negotiated rates is hereby granted in part, as discussed in the body of this order.

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