3. What are the effects on Michigan of belonging to multiple regional transmission organizations? What voting structures are used in both systems, and how many votes in each system are allocated to Michigan entities?
1. The primary effect of Michigan utilities participating in multiple regional transmission organizations (RTO's) is that the efficient dispatch of transmission and generation is limited between the Lower Peninsula of Michigan and other states.
2. The Voting Structure of MISO and PJM are similar for policy recommendations, but very different for the election of Board members. For Board member elections, each holding company in MISO is entitled to one vote, and each vote has the same value as every other vote. At PJM, each company gets one vote during Board elections, but the voting is adjusted according to provisions in the PJM Operating Agreement. One of the primary differences in the PJM and MISO stakeholder processes is that in PJM the stakeholders must approve all tariff changes before they are filed with the Federal Energy Regulatory Commission (FERC), while in MISO the stakeholder votes are considered "advisory" only.
3. The sum of the Lower and Upper Peninsulas make up approximately 20.7% of the current MISO market. AEP is one of the largest Transmission Owners in PJM but, due to PJM's voting structure, controls 2% of the vote.
- Joint response from Consumers Energy and MEGA
Our Michigan companies only operate within the MISO, so our comments focus on that Regional Transmission Organization ("RTO").
In MISO there are several stakeholder sectors that each vote on key issues of relevance. A list of voting stakeholders is found here: https://www.misoenergy.org/Library/Repository/Meeting%20Material/Stakeholder/Committee%20Documents/Member%20Voting%20List.pdf
A list of the MISO stakeholder sectors and their weighting is found in the MISO stakeholders governance guide here: https://www.misoenergy.org/Library/Repository/Meeting%20Material/Stakeholder/Committee%20Documents/Stakeholder%20Governance%20Guide.pdf
ITC participates in the transmission owner sector, and only has one has vote in that sector for MISO matters. ITC also has only one vote when electing new MISO board members. This structure only allows the company a limited say in MISO despite representing over 25% of the MISO footprint when our ITC Midwest operating company is included.
- Kwafo, ITC Holdings Corp