IPWG: Attachment GGG - Merchant HDVC Self Fund (20210713)

Clean Grid Alliance Comments to Adding TO Self-Funding to MHVDC Projects
August 3, 2021

Clean Grid Alliance appreciates the opportunity to provide comments on ITC’s proposal to the IPWG to add TO Self-Funding to MHVDC Projects. TO Self-Funding creates barriers to interconnection projects today by adding significant additional costs to projects, while providing absolutely zero value in return to those projects.  In some cases, the cost adder can be significant enough to prevent a project from moving forward. Quite frankly, this cost-adder is being debated in the courts since the claims it was based on were not reviewed properly or established as fact in the record, while TO Self-Funding has created barriers to the construction of much needed transmission for interconnection of generation, particularly impacting renewable generation projects. Although this debate is beyond the scope of these comments, it’s important to understand that this proposed cost-adder will create yet another a financial barrier with no added  value to MHVDC projects at a time when these projects are greatly needed and bring significant benefits to MISO transmission system, but already face extensive barriers. 

CGA enquired during the IPWG presentation on this topic why it is proposed to add TO Self-Funding to HVDC TO-TO (transmission Owner – Transmission Owner) interconnections when AC TO-TO interconnections are not assessed TO Self-Funding. MISO confirmed that in regard to AC TO-TO interconnection, Self-Funding is not applied -neither to neighboring incumbent TOs, nor independent AC transmission developers. Ultimately the MHVDC project developer will become a MISO Transmission Owner (if not already one), so it remains unclear why HVDC TO-TO connections are proposed for different treatment. Inconsistent application of a self-funding policy will create opportunities for undue discrimination that favors incumbent TOs own connections, leading to a policy that is not just and reasonable and cannot be approved by FERC.  We look forward to a follow up presentation with additional information on the justification for this proposal, given that it appears to be contrary to existing rules and precedent. 

Sincerely,

Rhonda R. Peters, Ph.D.

Technical Consultant to Clean Grid Alliance 

TO Feedback:  Attachment GGG Self-Fund Modifications

August 3, 2021

The TOs thank MISO for the opportunity to provide feedback requested on the July 13, 2021 Interconnection Process Working Group (IPWG) meeting presentation on modifications to Attachment GGG to provide consistency for self-funding.  

As background, Attachment GGG contains Merchant HVDC (MHVDC) Transmission Connection Procedures was adopted in 2018 and approved in Docket No. ER18-1410.  It includes a pro forma Transmission Connection Agreement (TCA) for use between the TO and a merchant developer if the merchant project is delivering power outside of MISO.  If an MHVDC line is injecting power into MISO, similar to a generator interconnection, then Attachment X applies, and a GIA will be executed.  If a GIA is executed, the connecting TO will be able to elect self-funding of Network Upgrades.  If a MHVDC project is not injecting power, then Attachment GGG requires a TCA for the MHVDC line to connect to MISO.  Unlike Attachment X and the GIA, Attachment GGG and the TCA do not currently contain self-funding provisions for Network Upgrades or Necessary Upgrades required to mitigate constraints caused by the withdrawal of power.  This omission may have occurred because Attachment GGG was introduced when the MISO Tariff provisions on self-funding were pending remand at FERC.

At the July IPWG meeting, stakeholder discussion was initiated regarding amendment of Attachment GGG to allow TO funding of Network Upgrades and Necessary Upgrades necessary for the connection of MHVDC facilities in the TCA. 

• The TOs support these amendments and believe they would resolve the current inconsistency in the Tariff that allows for TO funding of upgrades if a MHVDC facility is injecting power but not for a facility that is withdrawing power or only connecting to the transmission system. 
• The amendments are also supported by existing FERC precedent (See Ameren Services Company, et al. v. FERC, 880 F.3d 571 (D.C. Cir. 2018); Midcontinent Independent System Operator, Inc., 164 FERC ¶ 61,158 (2018).) 
• The TOs also support the proposed amendment to provide consistency for self-funding across all of the various types of network upgrades under the MISO tariff.