IPWG: GIA Interim Milestones - BPM-015 Revisions (20210921)

EDFR supports MISO moving forward to allowing GIA milestone changes in cases where there is no harm to downstream projects. The language proposed on slide 6 is ok, but 3) could be edited slightly, proposed changes below:

(3) Interconnection Customer demonstrates an absence of any significant potential for harm to other queued projects. Factors that may be considered: whether changes specifically affect [Network Upgrades aside from those at the POI]; whether proposed change would satisfy a material modification standard; whether POI is shared by any downstream projects (i.e., no dependencies) [and the delay in the milestone would impact the timing for in-service of the downstream project]; whether the particular project is appearing in MTEP models COMMENT- why does this matter, especially if just new switchyard to tap line?]; no Network Upgrades or affected system upgrades assigned to the project [COMMENT - the project requesting GIA milestone changes should maintain schedule for NUs elsewhere on the system (i.e. non-POI NUs)].

ITC appreciates the opportunity to submit feedback on the Proposed GIA Milestone Changes and has the following comments:

ITC concurs with MISO’s proposal to allow Interconnection Customers to seek GIA Milestone Changes provided:

• the Interconnection Customer provides a written statement identifying the proposed change,
• the Interconnection Customer and the Transmission Owner both agree on the specific changes being proposed
• the Interconnection Customer demonstrates the absence of any significant potential for harm to other queue projects.  Both MISO and the Transmission Owner have the right to review the evaluation for any potential harm.

Transmission Owner Sector Comments on GIA Interim Milestones - BPM-015 Revisions 

October 12, 2021

The MISO Transmission Owners Sector provides the following feedback on MISO's initial responses to questions and provide additional comments regarding GIA Interim Milestones - BPM-015 Revisions, as requested at the September 21, 2021 Interconnection Process Working Group (IPWG) meeting.

The Owners thank MISO for revisiting this issue and providing flexibility to Interconnection Customers and Transmission Owners to find solutions to issues that may arise during construction that do not impact other projects downstream. The Owners appreciate that MISO’s proposal allows the parties an opportunity to demonstrate to MISO that there is a benefit to the system with the delay in proposed Section 7.3 BPM-015 language regarding “Interconnection Customer Delays.”  However, some Owners are concerned that because the project in question would always be included in the network models, and the cut-in would always be a Network upgrade, as written, the proposed language has the potential to essentially deny any request to modify interim milestones.

The Owners thank MISO for the opportunity to comment.

Clean Grid Alliance Comments on GIA Interim Milestones
Oct 12, 2021 

Clean Grid Alliance appreciates the opportunity to provide comments to MISO on GIA Interim Milestones. We appreciate MISO’s flexibility on this very impactful topic/issue and believe the changes will lead to efficiencies for both interconnection customers and transmission owners alike. 

Sincerely,

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