In the March 16 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on the Fuel Change proposed Draft Tariff language. Please provide feedback by March 30.
March 25, 2021
Invenergy LLC ("Invenergy") appreciates the opportunity to provide feedback on MISO's Fuel Change Material Modification Criteria proposal, presented at the March 16, 2021 IPWG.
Generally speaking developers need as much flexibility as possible in the interconnection process on the front end as development is non-linear and projects and demand for specific generating types by our customers can change on a dime. We believe if a project can demonstrate that a fuel change would not harm other interconnection customers it should still be permitted at any point in the interconnection process but we understand MISO's desire for certainty and consistency in fuel type once the study process has kicked off. To that end - we believe there is still room for additional flexibility prior to studies kicking off that will not create the type of disruption that MISO is trying to avoid.
MISO's current proposal would allow ICs to drop one fuel type prior to Phase 1 start but would not allow an IC to change fuel type prior to Phase 1 start due to concerns about gaming site control. If an IC is planning to change its fuel type to a generating technology that requires less land than its original request (wind --> solar or storage, solar ---> storage) and does so prior to study kick off, Invenergy sees no reason why that should not be allowed and feels this is similar to what MISO has already agreed to allow with hybrid requests. In both cases no additional site control is needed and a quick review of the site reconfiguration plans should not be a significant burden on MISO. This is a reasonable accommodation that MISO can grant to interconnection customers that will not have a negative financial impact on other projects in the queue. Given FERC's directive to allow fuel change requests at any time in the DPP this seems like a minor accommodation.
Respectfully,
Nicole Luckey
Vice President, Regulatory Affairs
Invenergy LLC
Clean Grid Alliance Comments on Fuel Change Material Modification
March 30, 2021
Clean Grid Alliance appreciates the opportunity to provide comments on MISO’s March IPWG presentation regarding Fuel Change Material Modification. We appreciate MISO’s effort to innovate creative solutions to address to the FERC Order requiring fuel changes be evaluated as a Material Modification and not just de-facto rejected. The CGA membership strongly supports allowing Surplus Interconnection requests after Decision Point 2 (moved up from after GIA execution) and also the ability to drop one or more fuel sources of a hybrid request prior to study kick-off.
Additionally, Clean Grid Alliance would like to request that MISO consider changes prior to study kick-off such as wind to solar or battery (in whole or in part of the project) and solar to battery that do not require an increase in site control. This change is very similar in nature to a hybrid project dropping a fuel source prior to study kick-off, since no additional site control is required for such changes.
We appreciate MISO’s consideration of this request.
Sincerely,
Rhonda Peters, Ph.D.
Consultant for Clean Grid Alliance
NextEra Energy Resources, LLC (“NextEra”) appreciates the opportunity to comment on the Fuel type change material modification criteria proposal. NextEra continues to support MISO’s efforts to address FERC’s ruling on addressing fuel type changes in the queue. NextEra believes that the current proposal to allow for the use of Surplus Interconnection after DPP Phase II, and the ability to drop one or more components to a hybrid request prior to study kickoff addresses a lot of stakeholder needs/requests. NextEra believes that the parameters outlined in the current proposal ensures that the existing queue will not incur further delays and will allow for MISO to continue its efforts to reduce the overall Generator Interconnection timeline.
WPPI Energy offers suggested clarifying edits to the proposed language in red-line Word document submitted separately.