Wind energy needs fair access to the electric transmission system that delivers power to market. But the "rules of the road" for this road to market were written for traditional forms of generation such as coal, nuclear and natural gas. The old rules tend to penalize new competitors and new technologies. Intermittent generators like wind power, which produce electricity only when the wind blows, often pay substantial penalties as a result, effectively keeping them out of the market. And new generators can be required to pay the full cost of upgrading the transmission system, giving a huge advantage to the existing generators. Finally, while there are regional transmission planning groups, their decisions to upgrade the wires usually focus on technical problems, and may not reflect other goals like environmental benefits or state renewable energy preferences and requirements.

Wind on the Wires is working with regulators to level the playing field for wind power by:

1) Developing a "high wind" scenario for the upper Midwest. The high wind scenario will help determine how the transmission system may need to be improved or expanded to accommodate the development of 10,000 MW of wind power in the upper Midwest. The results will help inform state and federal regulators, the public, and other stakeholders about the infrastructure necessary to deliver significant amounts of wind power to market.

2) Ensuring that new transmission lines constructed for wind power actually carry wind-generated electricity. In December 2001, Xcel Energy filed an application for 4 new large high voltage transmission lines in Southwest Minnesota to provide additional capacity for wind power. WOW crafted a series of conditions to ensure, to the extent possible, that the new transmission lines would be used for their intended purpose: to carry wind power. In January 2003, the Minnesota Public Utilities Commission granted to 4 new transmission lines and attached the conditions crafted by WOW.

3) Working with state and federal regulators to ensure rules governing transmission access are equitable for all generators. For instance, WOW staff testified at a FERC hearing regarding regional interconnection "queue" issues. WOW, in conjunction with colleague organizations, is participating on the development of regional tariff issues at the MISO to ensure that the market rules allow wind power to fairly participate in the marketplace.

Downloadable Documents

May 18 , 2010
Establishing a Fair and Competitive Cost-Allocation Method for Transmission Investment
The Midwest Independent System Operator (Midwest ISO) has released a new draft proposal for allocating costs for electricity transmission lines in the Midwest. The proposal comes after more than a year of negotiation among transmission owners, state regulators, utilities, generation developers, power marketers, environmental organizations and other stakeholders. While the Midwest ISO proposal purports to support Midwest wind development and public policy, Wind on the Wires still has strong concerns, many of which are shared by a number of wind industry stakeholders.

As the Midwest ISO considers how to allocate the costs for new transmission lines, the economic development, jobs, and tax revenue that wind development brings to communities could well hang in the balance. Midwest wind power will also play an important role in making the nation more energy independent and secure, yet limited capacity on the existing transmission grid and uncertainty over the economics of expanding the grid has sharply curtailed development of the Midwest's emerging wind power industry.

The new draft proposal from the Midwest ISO fails to address many of the original concerns relating to wind power, which were outlined in a series of letters over the past year. The concerns include prohibitive transmission costs for new wind development that create a competitive disadvantage for the Midwest as compared to other regions of the country, and lack of a clear transition process between the old cost allocation method and new method for emerging wind energy projects.

An informal survey of Wind on the Wires member wind developers revealed that companies will be forced to take a hard look at development plans in the Midwest if the Midwest ISO fails to adopt a favorable cost allocation policy.

In addition to the economic concerns, the eventual success or failure of the renewable energy goals outlined by the regional Midwest Governors’ Agreement and in individual states could hinge on how the issue of transmission costs is eventually settled.

Below are some of the recent comment letters Wind on the Wires submitted to MISO on three competing proposals for transmission investment:

1. May 19 – WOW Response to Latest MISO Proposal for Cost-Allocation (RECB III)

2. April 27 – WOW response to revised Cost Allocation Recovery Process proposal

3. April 15- Cover letter and general principles related to WOW response to MISO Injection-Withdrawal proposal and Transmission Owners Cost Allocation proposal

4. April 15 – In-depth comments of Wind on the Wires Regarding the MISO Injection-Withdrawal and Transmission Owners Cost Allocation proposals

5. March 23 - Wind on the Wires Initial Comments on the Midwest ISO Transmission Owners’ Cost Allocation Framework

6. March 22 - Wind on the Wires Initial Comments on the Midwest ISO’s Injection-Withdrawal Proposal

April 4, 2008
ITC Midwest FERC Filing
ITC Midwest filed to reimburse new generators 100% for Network Upgrades. WOW and AWEA will be filing supportive comments at FERC on this request. ITC Midwest is a transmission-only company. They purchased the transmission assets formerly owned by Interstate Power & Light in Iowa and Minnesota.

Attached PDF
1. ITC Midwest April 4, 2008 FERC Filing

January 2008
Minnesota Biennial Transmission Plan 2007
The 2007 Minnesota Biennial Transmission Projects Report and the Renewable Energy Standards Report (Report) was filed with the Minnesota Public Utilities Commission on November 1, 2007,
Docket No. E-999/M-07-1028. WOW submitted comments on these filed reports mainly on sections
related to the transmission needed to comply with the Minnesota Renewable Energy Standard (RES).

Attached Link and Files
1. To search the MN PUC for Case Control Sheet:
Click on Link: https://www.edockets.state.mn.us/EFiling/DocumentSearch.do
Enter Docket No. 07-1028 (enter "07" in the "year" box) and (enter "1028" in the "number" box)
Click on the Search button at the bottom of the page (no need to enter a document type)
2. WOW Comments January 15, 2008
3. WOW Reply Comments March 3, 2008

December 10, 2007
Xcel Energy Renewable Energy Plan
Xcel filed its Renewable Energy Plan with the Minnesota Public Utilites Commission,
Docket No. E-002/M-07-1558. Xcel's initial filing can be accessed by searching the docket number on the case control sheet link below. Wind on the Wires is participating in this docket.

Attached Link and Files
1. To search the MN PUC for Case Control Sheet:
Click on Link: https://www.edockets.state.mn.us/EFiling/DocumentSearch.do
Enter Docket No.07-1558 (enter "07" in the "year" box) and (enter "1558" in the "number" box)
Click on the Search button at the bottom of the page (no need to enter a document type)
2. WOW/IWLA-MWO/Fresh Energy/MCEA Comments February 11, 2008
3. WOW/IWLA-MWO/Fresh Energy/MCEA Reply Comments March 3, 2008

October 29, 2007
Multi-State Tracking and Trading System for Renewable Energy Credits
(also known as MRETS)
Multi-State Tracking and Trading System for Renewable Energy Credits, Dockets Nos. E-999/CI-04-1616
and E999/CI-03-869. These dockets are related. Wind on the Wires has filed comments and reply comments that should appear under both docket numbers.

Attached Link and Files
1. To search the MN PUC for Case Control Sheet:
Click on Link: https://www.edockets.state.mn.us/EFiling/DocumentSearch.do
Enter Docket No. 04-1616 (enter "04" in the "year" box) and (enter "1616" in the "number" box)
Click on the Search button at the bottom of the page (no need to enter a document type)
Repeat search for Docket 03-869
2. WOW Initial Comments 10-01-07
3. WOW Reply Comments 10-29-07

August 16, 2007
CapX2020 Certificate of Need for three 345 kV Transmission Lines
CapX2020 Initiative, Capital Expenditures by the Year 2020, is a coordinated effort to develop an efficient approach to improving the regional transmission system. Xcel Energy and Great River Energy filed an Application to the Minnesota Public Utilities Commission for Certificates of Need for three 345kV Transmission Line Projects and Associated System Connections, Docket No. ET02, E002/CN-06-1115. WOW has filed Comments, Reply Comments and various other documents in this docket. A current list of filed documents can be found on the MN PUC website; see link below.

Attached Link
1. To search the MN PUC for Case Control Sheet:
Click on Link: https://www.edockets.state.mn.us/EFiling/DocumentSearch.do
Enter Docket No. 06-1115 (enter "06" in the "year" box) and (enter "1115" in the "number" box)
Click on the Search button at the bottom of the page (no need to enter a document type)
All "Public" documents can be viewed and/or downloaded.
2. For more information on CapX2020 projects and initiatives: http://www.capx2020.com/index.html

Windpower Advanced by Powerline Approval
Wind power in Minnesota was advanced dramatically on January 31, 2003. A new powerline designed to carry wind energy from the Buffalo Ridge to the metro area was approved by utility regulators at the Public Utility Commission (PUC). The powerline proposed by Xcel Energy was approved with conditions developed by Wind on the Wires and is projected to be in service in 2006.

Attached PDFs
1. 345_Order.pdf
2. 345_presentation.pdf

MISO Board Approves 2003 Transmission Expansion Plan
On June 23, 2003, the Board of Directors of the Midwest Independent System Operator (MISO) unanimously endorsed the 2003 Transmission Expansion Plan that includes $1.3 billion in transmission grid improvements for regional reliability. The transmission improvements will be made by MISOﾒs transmission owners in the region to address local reliability needs, load growth and connection of new generation projects to the grid. MISO is the regional entity that is responsible for ensuring the reliable operation of the wholesale electric transmission system and is headquartered in Carmel, Indiana.

The plan, known as the MISO Transmission Expansion Plan (MTEP), analyzed four separate generation development scenarios and 11 different transmission concepts. One of the four generation scenarios was a ﾓHigh Wind Scenarioﾔ provided by Wind on the Wires and the American Wind Energy Association in the Midwest Wind Development Plan document. The High Wind Scenario called on MISO to model transmission infrastructure necessary to export to market approximately 10,000 MW of wind energy from the upper Midwest. A copy of the Midwest Wind Development Plan is available here: http://www.midwestiso.org/plan_inter/documents/expansion_planning/MTEP%202002-2007%20Board%20Approved%20061903.pdf

The MTEP found that building new wind generation, as well as other types of generation, could result in lower marginal costs of wholesale energy provided additional transmission investment is made. The MTEP also found that transmission expansion could result in improved delivery of the most efficient existing and new resources. While the 2003 MTEP contains much analysis, MISO plans to do additional work on several ﾓexploratory transmission scenariosﾔ to determine whether it would be beneficial to move forward with identified segments of transmission. Wind on the Wires is interested in further analysis and development of several of the exploratory transmission configurations.

2002 Midwest Wind Development Plan
Wind on the Wires (WOW) works with wind energy companies and stakeholders active in the region to develop projections of potential wind development in the upper Midwest. The projections include ocations, markets, and costs. The purpose of the first Midwest Wind Development Plan (attached below), developed in 2002, was for input into MISOﾒs regional transmission expansion planning process. WOW prepared a ﾓhigh windﾔ scenario of 10,000 MW for MISOﾒs regional transmission expansion plan, as a means of identifying what transmission infrastructure is necessary to deliver wind energy to market. WOW estimated in 2002 that 5,500 to 10,000 MW of new wind power could be developed in the Midwest over the coming decade. Wind on the Wires is currently updating our 2002 Midwest Wind Development Plan.

Attached PDF
1. 2002_Midwest_Wind_Development_Plan_060102.pdf