[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-0-en-105":3,"doc-seo-144430-105":59,"doc-detail-144430-en":117},{"code":4,"msg":5,"data":6},0,"success",[7,13,18,23,28,33,38,43,48,51,55],{"id":8,"doc_module":4,"doc_module_name":9,"category_name":10,"show_sort_weight":11,"slug":12},1,"Document","Story & Novel",90,"story-novel",{"id":14,"doc_module":4,"doc_module_name":9,"category_name":15,"show_sort_weight":16,"slug":17},2,"Literature",80,"literature",{"id":19,"doc_module":4,"doc_module_name":9,"category_name":20,"show_sort_weight":21,"slug":22},4,"Exam",70,"exam",{"id":24,"doc_module":4,"doc_module_name":9,"category_name":25,"show_sort_weight":26,"slug":27},5,"Comic",60,"comic",{"id":29,"doc_module":4,"doc_module_name":9,"category_name":30,"show_sort_weight":31,"slug":32},6,"Technology",50,"technology",{"id":34,"doc_module":4,"doc_module_name":9,"category_name":35,"show_sort_weight":36,"slug":37},7,"Healthcare",40,"healthcare",{"id":39,"doc_module":4,"doc_module_name":9,"category_name":40,"show_sort_weight":41,"slug":42},8,"Research & Report",30,"research-report",{"id":44,"doc_module":4,"doc_module_name":9,"category_name":45,"show_sort_weight":46,"slug":47},9,"Religion & Spirituality",20,"religion-spirituality",{"id":46,"doc_module":4,"doc_module_name":9,"category_name":49,"show_sort_weight":46,"slug":50},"World Cup","world-cup",{"id":52,"doc_module":4,"doc_module_name":9,"category_name":53,"show_sort_weight":52,"slug":54},10,"Lifestyle","lifestyle",{"id":56,"doc_module":4,"doc_module_name":9,"category_name":57,"show_sort_weight":24,"slug":58},19,"General","general",{"code":4,"msg":60,"data":61},"ok",{"site_id":62,"language":63,"slug":64,"title":65,"keywords":66,"description":67,"schema_data":68,"social_meta":110,"head_meta":112,"extra_data":114,"updated_unix":116},105,"en","environmental-sectors-informal-feedback-on-lrtp-tranche-2-business-case-benefit-metrics","Environmental Sector’s Informal Feedback on LRTP Tranche 2 Business Case Benefit Metrics","","Environmental Sector provides informal feedback on LRTP Tranche 2 business case benefit metrics identified by MISO, assessing whether an 11-metric set captures transmission value for the MISO Midwest subregion. The feedback supports additions while recommending recognition of hard-to-monetize benefits in benefit-to-cost analysis. It also references FERC NOPR RM21-17-000 to urge inclusion of any missing proposed metrics. A key recommendation is adding public health impacts from air pollution reductions (NOx, SO2, PM2.5).",{"@graph":69,"@context":109},[70,84,100],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/environmental-sectors-informal-feedback-on-lrtp-tranche-2-business-case-benefit-metrics/144430/",{"url":83,"name":65,"@type":85,"author":86,"headline":65,"publisher":89,"fileFormat":92,"inLanguage":63,"description":67,"dateModified":93,"datePublished":94,"encodingFormat":92,"isAccessibleForFree":95,"interactionStatistic":96},"DigitalDocument",{"name":87,"@type":88},"Đào","Person",{"url":74,"name":90,"@type":91},"DocShare","Organization","application/pdf","2026-09-11","2026-08-25",true,{"@type":97,"interactionType":98,"userInteractionCount":14},"InteractionCounter",{"@type":99},"ViewAction",{"@type":101,"mainEntity":102},"FAQPage",[103],{"name":104,"@type":105,"acceptedAnswer":106},"Why does the Environmental Sector recommend including air pollution reduction in Tranche 2 benefit metrics?","Question",{"text":107,"@type":108},"Decarbonization reduces criteria air pollutants that affect human health, including NOx, SO2, and PM2.5. The document emphasizes quantifiable public health benefits and unequal exposure burdens, arguing these should be included when calculating transmission benefits for Tranche 2.","Answer","https://schema.org",{"og:url":83,"og:type":111,"og:title":65,"og:site_name":90,"og:description":67},"article",{"robots":113,"canonical":83},"index,follow",{"doc_id":115,"site_id":62},144430,1787702099,{"code":4,"msg":5,"data":118},{"doc_id":115,"user_id":119,"nickname":87,"user_avatar":120,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":121,"file_id":122,"file_url":123,"file_type":124,"file_size":125,"view_count":14,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":34,"language":126,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":127,"faqs":128,"seo_title":129,"seo_description":67,"update_tm":116,"read_time":130},1374402968488,"https://ap-avatar.wpscdn.com/davatar_29158cc5080c5b710cf443261637dec0","ENVIRONMENTAL SECTOR’S INFORMAL FEEDBACK ON LRTP TRANCHE 2 BUSINESS CASE BENEFIT METRICS  \nA. Is the set of eleven benefit metrics sufficient in scope to capture the transmission value provided to MISO Midwest subregion?  \nMISO identified the following 11 benefit metrics at its March 10, 2023 LRTP Workshop  \n1. Avoided risk of load shedding for extreme weather events  \n2. Avoided transmission investment  \n3. Capital cost savings from reduced losses  \n4. Decarbonization  \n5. Resource adequacy savings  \n6. Avoided capital cost of local resource investment  \n7. Congestion and fuel savings  \n8. Production cost savings due to reduced energy losses  \n9. Production cost savings from facility outage impacts  \n10. Ramping flexibility for variability of renewables  \n11. Reliability benefits  \nWe applaud MISO’s continuing efforts to capture all of the benefits provided by transmission and especially applaud the addition of new metrics.  \nThe Environmental Sector historically has provided additional metrics to those identified by MISO and list those metrics here:  \n1. Wheeling out revenues, which capture some transmission upgrades, will increase transfer capabilities to neighboring regions and this increases wheeling revenues that pay for some of the project’s costs  \n2. Market-to-Market Payment Cost Savings  \n3. Environmental justice considerations  \n4. Public health benefits including air pollution emissions  \n5. Increases in competition  \nWe recognize that some of these benefits are difficult to monetize, and therefore, may not be appropriate for calculating the benefit-to-cost ratios. Nevertheless, they are benefits brought by transmission that should be somehow recognized in MISO’s business case analysis.  \nWe also note that FERC released a list of benefit metrics in its April 21, 2022 Notice of Proposed Rulemaking on Transmission Planning and Cost Allocation. Docket No.  \nRM21-17-000 (NOPR) . FERC noted that not considering, among other things, abroader set of benefits could result in unjust and unreasonable and unduly discriminatory and preferential rates. NOPR ¶¶ 35, 53-55. FERC’s list of proposed metrics are as follows:  \n(1) avoided or deferred reliability transmission projects and aging infrastructure replacement;  \n(2) either reduced loss of load probability or reduced planning reserve margin;  \n(3) production cost savings;  \n(4) reduced transmission energy losses;  \n(5) reduced congestion due to transmission outages;  \n(6) mitigation of extreme events and system contingencies;  \n(7) mitigation of weather and load uncertainty;  \n(8) capacity cost benefits from reduced peak energy losses;  \n(9) deferred generation capacity investments;  \n(10) access to lower-cost generation;  \n(11) increased competition; and  \n(12) increased market liquidity.  \nNOPR ¶ 184. The NOPR then proceeds to describe how each of these metrics can be calculated. We urge MISO to add any metrics that are included in FERC’s list that are not already captured by MISO’s metrics.  \nB. If not, what other metrics should be considered?  \n1. Air Pollution (NOx, SO2 , and PM2 5) Reduction  \nMISO’s inclusion of decarbonization as a benefit metric in evaluating Tranche 1 was a watershed moment and the Environmental Sector applauds MISO’s valuation of carbon reductions. Decarbonization not only yields benefits by reducing greenhouse gas emissions, but it also results in immediate and local reductions of criteria air pollutants. Pollutants that can be reduced from decarbonization of electricity generation include NOx, SO2 , and PM2.5 , which are federally regulated due to their impact on human health.  \nThe concrete and quantifiable benefits to public health of air pollution in the MISO region should be included as a metric when calculating benefits for Tranche 2 transmission.  \nExposure to fine particulate matter (PM2.5) causes cardiovascular and respiratory health impacts, including 100,000-200,000 premature deaths in the U.S. every year1 and is atop environmental ris","cbCaioerHuJt8Edt","https://ap.wps.com/l/cbCaioerHuJt8Edt","pdf",169461,"English","# Environmental Sector’s Informal Feedback on LRTP Tranche 2 Business Case Benefit Metrics\n## A. Are the eleven benefit metrics sufficient?\n## B. If not, what other metrics should be considered?\n## 1. Air Pollution (NOx, SO2, and PM2.5) Reduction","[{\"question\":\"Why does the Environmental Sector recommend including air pollution reduction in Tranche 2 benefit metrics?\",\"answer\":\"Decarbonization reduces criteria air pollutants that affect human health, including NOx, SO2, and PM2.5. The document emphasizes quantifiable public health benefits and unequal exposure burdens, arguing these should be included when calculating transmission benefits for Tranche 2.\"}]","Environmental Sector’s Informal Feedback on LRTP Tranche 2 Business Case Benefit Metrics | PDF",18]