IPWG: Generator Replacement Transfer Restriction Proposal and Tariff (20210426)

Clean Grid Alliance Comments on Generator Replacement Transfer Restrictions

Interconnection Process Working Group

May 10, 2021

Clean Grid Alliance appreciates the opportunity to provide comments to MISO on Generator Replacement Transfer Restrictions. We appreciate MISO’s proposed solution to address the issue of Generator Replacement projects not being able to receive tax equity and other credits as an unintended consequence of the ownership transfer restrictions. We believe MISO has found a balance that maintains the intent of the Generator Replacement Order, while also allowing renewable projects to obtain the tax equity they would otherwise qualify for. 

We encourage MISO to move forward with this proposed change quickly, as the Generator Retirement and Replacement process has strict timelines and many generators are planned for retirement. Without this change, opportunities may be lost due to the unintended consequences of the original Order. 

Sincerely,

Rhonda Peters, Ph.D.

Technical Consultant to Clean Grid Alliance

WPPI Energy offers the following comments on the proposed tariff changes:

• 3.7.1(vi)(a)(3) includes “transfer(S)” – should be “transfer(s)”
• 3.7.1 does not require addition, in the last sentence, of “or Section 3.7.1.(vi)(a)” since or Section 3.7.1.(vi)(a) is proposed to be part of Section 3.7.1.(vi), which is already specified in the previous clause.

NextEra Energy Resources, LLC (“NextEra”) appreciates the opportunity to comment on the Generator Replacement transfer restriction proposal.  NextEra continues to support MISO’s proposal to allow for limited changes to the current Generator Replacement policy transfer restrictions.  NextEra is supportive of the latest changes that MISO presented at the April Interconnection Process Working Group (“IPWG”) as they address legitimate concerns, all the while ensuring that the underlying policy and its intended purpose remains intact.  NextEra continues to support MISO’s swift timeline to enact these changes, as the generator replacement process is likely to be utilized much more frequently as energy providers continue to evaluate their energy mix and start to shift towards alternate energy sources.

Alliant Energy continues to strongly support MISO’s proposed exception to the Generator Replacement process transfer restriction.  This change will be very useful in enabling certain project financing transactions and in helping to monetize the Investment Tax Credit for the benefit of customers.  The modifications which have been made to the proposal following up on the March IPWG are reasonable and overall improve the proposal.  Alliant Energy requests that MISO expedite the timeline of filing this proposal to FERC.  Time is of the essence in being able to take advantage of Investment Tax Credits.  Further, all of the feedback reviewed at the April IPWG meeting was supportive of the proposal.  Alliant Energy thanks MISO for the efforts made to date in moving this proposal forward.

May 10, 2021

Invenergy LLC ("Invenergy") appreciates the opportunity to provide comments to MISO on the April 26, 2021 presentation and tariff changes concerning Generator Replacement Transfer Restrictions.  Generally speaking Invenergy applauds MISO for its efforts to break down unnecessary barriers to generation replacement projects taking full advantage of the ITC via tax equity investors.  Invenergy believes that these changes will still prevent gaming while also allowing these transactions to occur.

It would be helpful if MISO would confirm that, where an Interconnection Customer has transferred an Existing Generating Facility and GIA have been transferred to a subsidiary pursuant to proposed Section 3.7.1(vi)(a), the Generating Facility Replacement could be submitted by that subsidiary, the original Interconnection Customer or another subsidiary to which the Replacement Generating Facility has been transferred pursuant to proposed Section 3.7.1(vi)(a).  In other words, it would be helpful if MISO could confirm that it will not be necessary for the entity that owns the Existing Generating Facility at the time of the Generating Facility Replacement request to submit the request.

Understanding that MISO needs to run these proposed changes through appropriate stakeholder channels, Invenergy would still urge that MISO make its FERC filing as soon as is practicable but no later than June or July of this year.

Thank you.

Nicole Luckey

Vice President, Regulatory Affairs

Invenergy LLC