In the Commission’s 2020 Order Accepting Report, Granting Variance, and Setting Additional Requirements, in Docket No. E999/M-19-205, Order Point 5(c). states:

The MTO shall provide a full discussion and analysis of next steps for identifying gaps between the existing and currently planned transmission system and the transmission system that will be required to meet the companies’ publicly stated clean energy goals. The MTO shall also address any need for new or expanded transmission to accommodate:

the public clean energy commitments of the MTO member utilities,

the requirements in all approved Minnesota resource plans, and

relevant Minnesota statutory goals.

9.2 Clean Energy Commitments

CLEAN ENERGY GOALS
American Transmission Company
Stated Goal	Comment
N/A – transmission only entity.	N/A
Central Minnesota Municipal Power Agency
Stated Goal	Comment
N/A	CMMPA currently provides approximately 43% of is energy needs from carbon free resources.
Dairyland Power Cooperative
Stated Goal	Comment
Dairyland is transitioning to a more diverse and balanced generation portfolio. In 2020, Dairyland’s Board of Directors approved a goal of a 50 percent reduction in carbon dioxide intensity by 2030 (from 2005 levels). Dairyland’s Sustainable Generation Plan focuses on system reliability and affordability for Dairyland’s members on the path to a low-carbon future.	Dairyland’s focus is on reducing economy-wide carbon emissions. Our initiatives to foster beneficial electrification, combined with our progressive investments in renewable resources to support this evolution. For example, Dairyland’s latest wind energy investment, the 52 MW Tatanka Ridge wind energy facility (South Dakota), began commercial operation in January 2021. Dairyland has a PPA for the entire 149 MW Badger State Solar facility, in development by Ranger Power in southern Wisconsin, which is expected to be in service in 2023. As we transition to a low-carbon future, safety and reliability remain at the forefront.

East River Electric Power Cooperative
Stated Goal	Comment
N/A	From 2013 to the date of this filing, East River’s power supplier, Basin Electric has entered into thirteen Power Purchase Agreements for a total of 1,514 MW of wind and solar power. Of that, 1,054 MW of wind projects were operating as of October 2021. A power purchase agreement for 142 MW was signed in 2019 for the Aurora Wind project which is scheduled to deliver energy starting January 1, 2023. Five solar Power Purchase Agreements totaling 318 MW were signed in late 2019 through June 2021. The Custer, West River, Wild Springs, and the Cabin Creek I and II Solar projects are scheduled to be operational between the of 2022 and 2024.
Great River Energy
Stated Goal	Comment
Serve its all-requirements member-owner cooperatives with energy that is 50 percent renewable by 2030.	Great River Energy is committed to an escalating, annual renewable energy goal for its all-requirements members: 25% until 2030, and 50% thereafter. Great River Energy has executed 910 MW of new wind purchases that will supply 3.5 million MWh per year, which combined with existing renewable purchases, is projected to exceed these renewable goals. These new wind projects and expected to be operational in 2021-2024 period, provide low cost energy to our member-owners, and reduce Great River Energy’s power supply carbon intensity.
ITC Midwest
Stated Goal	Comment
N/A – transmission only entity.	N/A
L&O Power Cooperative
Stated Goal	Comment
N/A	From 2013 to the date of this filing, L&O’s power supplier, Basin Electric has entered into thirteen Power Purchase Agreements for a total of 1,514 MW of wind and solar power. Of that, 1,054 MW of wind projects were operating as of October 2021. A power purchase agreement for 142 MW was signed in 2019 for the Aurora Wind project which is scheduled to deliver energy starting January 1, 2023. Five solar Power Purchase Agreements totaling 318 MW were signed in late 2019 through June 2021. The Custer, West River, Wild Springs, and the Cabin Creek I and II Solar projects are scheduled to be operational between the of 2022 and 2024.
Minnesota Power
Stated Goal	Comment
Deliver 70% renewable power supply by 2030, reduce carbon emissions 80% by 2035, with a vision for a 100% carbon-free energy future by 2050	At Minnesota Power, our EnergyForward strategy has reshaped the Company’s power supply from an energy mix that was 95 percent coal in 2005 to one that is now delivering 50 percent renewable energy to customers. The 2021 Integrated Resource Plan is Minnesota Power’s further vision for a sustainable path to a carbon-free energy future by 2050, and outlines bold next steps in the clean energy transition that are centered on a commitment to the climate, customers, and communities. Minnesota Power has committed to achieve an 80 percent reduction in carbon emissions by 2035 compared to 2005 levels, and outlined a goal of delivering 100 percent carbon-free energy by 2050. If approved, the 2021 Plan will facilitate a power supply that is 70 percent renewable in 2030, reduce carbon emissions by 80 percent by 2035 and result in a generation mix that is coal-free by 2035 while helping to ensure reliable and affordable power for Minnesota Power customers.
Minnesota Municipal Power Agency (MMPA)
Stated Goal	Comment
100% renewable when economical.	MMPA has no coal in its portfolio. MMPA’s renewable generation exceeded 22% of its load in 2020 and with its Walleye Wind PPA, renewable generation is projected to provide in excess of 40% of its load in 2023. MMPA regularly exceeds the MN state goals for carbon emissions reductions.
Minnkota Power Cooperative
Stated Goal	Comment
Committed to finding opportunities to reduce carbon emissions while maintaining system reliability.	Minnkota’s present electric generation capacity of 34% renewable and 8% hydroelectric resources provide a significant proportion of our energy portfolio that is non-CO2 emitting. Minnkota is also focused on development efforts for Project Tundra, which if constructed, would pioneer the effort to capture approximately 4 million metric tons of CO2 per year.

Missouri River Energy Services (including Hutchinson Utilities Commission, Willmar Municipal Utilities and Marshall Municipal Utilities)
Stated Goal	Comment
N/A	Creating a cleaner energy future is a top priority for MRES and our members, and we are delivering affordable, reliable, and ever-increasing clean energy to our members and their customers. Over the past 17 years, MRES has added renewable and carbon-free resources to our power supply mix, including nuclear, wind and solar resources. We recently completed a new clean, renewable, and reliable hydroelectric power plant near Pella, Iowa. And, MRES launched the Bright Energy Choices program on January 1, 2020, which allows members and their customers to choose 100 percent renewable or net-zero carbon-free energy through the purchase of Renewable Energy Certificates to offset the portion of their power supply that comes from fossil fuels. MRES continues to evaluate opportunities for additional clean energy resources as part of the ongoing commitment of MRES to the environment, and to help MRES members meet state renewable energy objectives/standards. In our decisions, we’ve focused on environmental stewardship, along with reducing risk, and increasing reliability.
Northern States Power Company d/b/a Xcel Energy
Stated Goal	Comment
Goal to reduce carbon emissions 80% by 2030, with a vision to provide 100% carbon-free electricity to customers by 2050.	Xcel Energy is the first major U.S. power company with an aspiration to provide 100% carbon-free electricity. We know that climate change is an urgent issue for many policy makers and investors and is a growing concern for our customers who look to Xcel Energy to act. It is a priority for us as well, and the reason we set an ambitious interim goal to reduce carbon emissions 80% by 2030 from the electricity we provide customers and aim to deliver 100% carbon-free electricity by 2050.
Otter Tail Power Company
Stated Goal	Comment
N/A	We continue to be innovative as we create a stronger, smarter energy grid and cleaner energy future. We project that by 2023 our customers will receive approximately 35% of their energy from renewable resources. Carbon emissions from our owned generation resources are targeted to be 50% lower than 2005 levels by 2025 and 97% lower than 2005 levels by 2050—all while keeping residential rates among the lowest in the nation.

Rochester Public Utilities
Stated Goal	Comment
100% renewable energy by 2030.	RPU will be redefining the energy mix used to supply RPU’s customers by procuring new energy and capacity sources for 2030. As published in RPU’s most recent resource plan, the RPU Board gave staff the direction to further pursue and investigate two options with 100% renewable energy. RPU is projected to procure the renewable energy from 50 MW of solar and 350 MW to 450 MW of wind, with capacity requirements being met from either 300 MW of battery storage or natural gas combustion turbines. The exact mix of wind, solar, and capacity resources will be determined at dates closer to 2030 based on available technologies and economics at that time. The mix of RPU ownership to PPAs will also be determined at a later date.
Southern Minnesota Municipal Power Agency
Stated Goal	Comment
80% carbon free in 2030.	SMMPA plans to retire Sherco 3 and cease owning coal generation in 2030. In place, SMMPA will be investing in significant levels of wind and solar (approximately 187MW of each). This will allow SMMPA to reduce its carbon emissions by nearly 90% from 2005 levels, pushing our total generation fleet to 80% carbon free in 2030. To move beyond 80% new technology and solutions will need to be designed, tested, and implemented. SMMPA is committed to exploring these new technologies, like storage, but we believe they should be deployed when cost-effective. Moving forward there will be a continued need for regional transmission investment to meet these goals. SMMPA is committed to being an active participant, with other utilities, to analyze, plan and build the transmission infrastructure necessary to support this transition to a carbon free future.

9.3 Approved Minnesota Resource Plans and Other Relevant Statutory Goals

Company Name	Last Approved IRP	Transmission Need Identified
Great River Energy	ET-2/RP-17-286	There was no transmission need identified as part of this IRP.
Minnesota Power	E015/RP-15-690	In approving the 2015 IRP, the Commission ordered Minnesota Power to remedy the transmission system issues related to the closure of Taconite Harbor units. The Taconite Harbor units are located in the “North Shore Loop” which has been an area of particular interest for transmission planning for Minnesota Power and is discussed in greater detail, including a list of associated transmission projects, in Section 5.3.
Minnkota Power Cooperative	ET6/RP-19-416	Minnkota staff will continue to analyze the cost-effectiveness of integrating demand side management programs and renewable energy resources into the NMPA and Minnkota’s Joint System power supply resource mix. There was no transmission need identified as part of this IRP.
MMPA	ET-6133/RP-18-524	There was no transmission need identified as part of this IRP.
Otter Tail Power Company	E017/RP-16-386	There was no transmission need identified as part of this IRP.
Xcel Energy	E002/RP-15-21	There was no transmission need identified as part of this IRP.

9.4 Ongoing Studies

MISO Long Range Transmission Planning (LRTP)
Long Range Transmission Planning (LRTP) is an essential element of planning the regional grid to be reliable and efficient over short and long-range planning horizons. The MISO MTO utilities participate in LRTP efforts at MISO. MISO is currently working to identify potential grid needs in support of the resource transformation underway and as contemplated under the MISO Futures. This extensive stakeholder process includes monthly workshops, periodic discussions at the Planning Advisory Committee, plus additional stakeholder meetings addressing cost allocation through the Regional Expansion Criteria and Benefits Working Group. Project recommendations resulting from this process will be then presented for Board of Director review and approval over several MTEP cycles as analyses proceed and recommendations are developed. Details of MISO’s Long Range Transmission Planning study progress are summarized in Sections 3.1 and 3.2 of the MTEP21 Report.

MTEP20 Report (misoenergy.org)