IPWG: Shared Interconnection Facilities (20210921)

Clean Grid Alliance Comments on Shared Interconnection Facilities
Oct 12, 2021 

Clean Grid Alliance appreciates the opportunity to provide comments to MISO on Shared Interconnection Facilities. We strongly support moving back the deadline from application to later in the process and also strongly support language that clarifies Transmission Owner notification is needed, but not Transmission Owner “approval”. We are open to the concept of a standard agreement template, but will evaluate and provide feedback when such a template is provided to stakeholders for review. 

We greatly appreciate MISO’s efforts and attention in working to improve this process. 

Sincerely,

Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance

EDFR thanks MISO for opening up this discussion. Having had to recently pursue this process for a project, we experienced some of the issues discussed in the presentation. EDFR would recommend:

• just the ICs, not the TOs, be signatories to the agreement
• a template in the BPM would be acceptable. Some TOs have a version of the agreement that appears to be slightly more developed than the MISO form and they may have some suggestions on the template.
• perhaps requiring the agreement before end of decision point 1 would be acceptable along with M3 milestone? This way it would be in place at time the facility study for upgrades at the POI would begin. Additionally by this time the projects have queue numbers which should be the reference to the projects in the agreement

The Transmission Owner should not be included in the Consent Agreement or referenced in the tariff language. 

*However, if MISO determines that the Transmission Owner must be a signatory to the Consent Agreement, we'd like to reserve our opportunity to respond accordingly.

TO Sector Comments on Shared Interconnection Facilities

October 12, 2021

The MISO Transmission Owners Sector provides the following feedback on MISO's initial responses to questions and provide additional comments regarding Shared Interconnection Facilities, as requested at the September 21, 2021 Interconnection Process Working Group (IPWG) meeting.

Transmission Owners agree with the areas of improvement suggested by MISO.  While operating arrangements may be relevant to a generator interconnection study, it is not clear that TOs have a need to know the Ownership arrangements before the GIA or be a signatory to the Shared Facilities Agreement.  To the extent that Ownership arrangements are relevant to the study itself, the current 2-day turnaround time for Owner review is not sufficient.

The Owners do not believe that Owner consent to a shared facilities arrangement is required initially, and that these arrangements should be between impacted Interconnection Customers (ICs).  However, the ICs should be expected to design the shared interconnection in such a way as to adhere to all applicable utility best practice and TO standards, and this requirement should be indicated in the resulting Facility Study (or Studies).  The TOs must also retain the right to evaluate and make changes to the proposed intersection arrangement during the Phase 2 Facilities Studies for the proposed interconnections.

Regarding the proposal to create a Shared Facilities Agreement template, which the Owners support, the current template structure that puts TOIF and ICIF in the same bucket and indicates the IC as the owner of both, which causes confusion for all parties involved.  It would be helpful to Include a statement noting that ownership of TOIF and ICIF will be determined by pending GIAs in order to avoid this confusion. 

Finally, if MISO elects to move forward with a template/ pro forma that would not require Transmission Owner signature, the Owners would like to ensure that TO are engaged in the development of the template/ pro forma throughout the process.

The Owners thank MISO for the opportunity to comment and look forward to additional discussion on this topic.

ITC appreciates the opportunity to submit feedback on the Shared Facilities Agreement proposal and has the following comments:

For the Shared Facilities Agreement, ITC would prefer that MISO continue to utilize a template that is editable.  If the form is a fixed format, there will always be circumstances that won’t fit the form.  ITC does believe the TO needs to be identified and notified of the intent and ultimately have the sign off ability for the configuration at or before the GIA.  We do not think this should be occurring at the time of the interconnection request as this is typically too early to assess the information provided.