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MISO should address Initial Commercial Operations Dates in Generator Interconnection Agreements (GIAs) due to: 

Under Section 4.4.4 of Attachment X, GIAs are required to have a Commercial Operations Date that is within 3 years of the date originally requested in the queue application. Section 4.4.4 also allows a three-year extension of the COD in the initial GIA to bring a project online before that GIA can be terminated for failure to meet Commercial Operations. This 3-year extension was meant to be a blanket extension for Interconnection Customers to deal with any project delays. In the event of significant delays in the study or significant delays in the ability of the TO to construct the required Network Upgrades, this rule can result in an unachievable COD. The 3-year window to bring the project online can be significantly reduced rendering the blanket extension unusable. Some stakeholders believe that the initial COD date should be allowed to be either 3 years from the requested date or the earliest date the Network Upgrades can be completed utilizing reasonable efforts by the Transmission Owner. The only way to “restore” the 3-year window under the current Tariff language would be to request a FERC Waiver of the provisions. This comes with some level of risk. There are several projects that are currently impacted by queue delays that are impacted by this rule. Because of the impact to present projects, we recommend that this topic is referred by the PAC to the IPWG for the August 2023 meeting.