In the April 26 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to send feedback on the concept of Generator Interconnection Agreement (GIA) changes - both general feedback and highlighted items from slide 5 (Proposed Criteria / Requirements) of the posted presentation.
Comments are due by May 10.
To: MISO Interconnection Process Working Group
From: Entergy Operating Companies
Subject: Requests to Adjust GIA Milestones
May 10. 2021
The following comments are offered by the Entergy Operating Companies[1] in response to the request for stakeholder feedback to the MISO Interconnection Process Working Group regarding requests to adjust GIA interim milestones. The Entergy Operating Companies submitted initial written comments on October 26, 2020, and supplemental comments on January 6, 2021. These additional comments address MISO’s presentation and request for input at the April 26, 2021, IPWG meeting.
COMMENTS
As explained in their prior comments, the Entergy Operating Companies (Entergy) understand MISO Tariff Attachment X and the pro forma Generator Interconnection Agreement (GIA) to currently provide Transmission Owners (TOs) and Interconnection Customers (ICs) flexibility to revise GIA interim milestones, subject to limitations. Consistent with this understanding, Entergy concurs with MISO’s April 26th position statements that the “Tariff provides adequate flexibility to address changes to milestones” and that “the adverse consequences [of interim milestone changes] may be minimal in some cases.”
Because some interim milestone changes will have only a minimal impact on downstream and future interconnection customers, and others will have no such impact, Entergy encourages MISO to apply its proposed criteria for making decisions about proposed milestone changes only to GIA interim milestone change requests that are reasonably expected to have a material impact on downstream and future interconnection customers. GIA milestone adjustments that would be expected to have a material impact would be those that impact system-wide network upgrades upon which downstream or future interconnection projects are reliant and cause such projects to experience a material delay or cost increase.[2]
If the proposed milestone changes are reasonably expected to have no impact or only minimal impact on downstream and future interconnection customers, then the proposed milestone changes should be permitted without application of MISO’s proposed criteria. GIA milestone adjustments that would be expected to not have a material impact would be those that are limited to interim payment milestones or changes that would extend the in-service date/backfeed date under the GIA by one year or less.
Entergy provides the following input in response to MISO’s requests for specific feedback on items in MISO’s April 26th proposal:
1. With respect to MISO’s proposed criterion that the “IC attest and demonstrate that project is commercially viable (e.g. PPA, commercial contract)”, MISO is “Seeking targeted stakeholder feedback on scope of documentation options that can show commercial viability”.
Entergy encourages MISO to adopt a flexible approach to its documentation requirements from the IC to demonstrate commercial viability. ICs experience a range of circumstances, so it may be overly limiting to identify a standard set of documents that MISO would require to establish commercial viability. If MISO elects to define a set of acceptable documents, it should also provide the opportunity for the IC to provide other or different documents or a detailed narrative explanation about its project’s commercial viability.
2. With respect to MISO’s proposed factors for an IC to demonstrates an absence of any significant potential for harm to other queued projects, MISO is seeking “targeted stakeholder feedback on the scope of these factors.”
Entergy encourages MISO to focus its inquiry about the existence of potential harm on system-wide network upgrades upon which downstream or future interconnection projects are reliant and cause such projects to experience a material delay or cost increase. As noted above, examples of system-wide network upgrades include new transmission lines, reconductors/rebuilds of existing transmission lines, installation of capacitor banks, or other upgrades required for generation capacity that are not related to the physical interconnection.
With regard to MISO’s valid concern with potential material impacts on downstream or future interconnection projects arising from milestone changes, Entergy notes that in previous comments it proposed simple conditions and information-sharing protocols intended to provide transparency about milestone changes to any potentially affected interconnection project.
Specifically, Entergy proposed that where a TO and IC would undertake a GIA interim milestone change, (1) the TO will document its agreement to adjust the GIA interim milestones and share the information with MISO; (2) the TO will update the MISO MOD tool to make the updated information available for modeling purposes; and (3) MISO will post information about GIA interim milestones, as provided by TOs, on the MISO Generator Interconnection page of the MISO website (https://www.misoenergy.org/planning/generator-interconnection/GI_Queue/) for the information of downstream and future interconnection customers. These information-sharing protocols would provide significant transparency to downstream and future interconnection project developers and substantially reduce the risk that interim milestone changes will have negative impacts.
[1]. Examples of system-wide network upgrades include new transmission lines, reconductors/rebuilds of existing transmission lines, installation of capacitor banks, or other upgrades required for generation capacity that are not related to the physical interconnection.
[2]. The Entergy Operating Companies are Entergy Arkansas, LLC; Entergy Louisiana, LLC; Entergy Mississippi, LLC; Entergy New Orleans, LLC; and Entergy Texas, Inc.
Clean Grid Alliance Comments on GIA Milestone Changes
Interconnection Process Working Group
May 10, 2021
Clean Grid Alliance appreciates the opportunity to comment on MISO’s April 26, 2021 presentation on GIA Milestone Changes. We strongly support MISO’s proposal to add flexibility into the process when there are no impacts to other interconnection customers. This is an extremely positive change supported by both transmission owners and interconnection customers.
We do have one question/comment in regard to the commercial readiness requirement. Since there is no impact to other interconnection customers and both the transmission owner and interconnection are in agreement, what purpose does this requirement serve? If MISO feels this requirement is necessary, would it consider an MOU or LOI as serving the intended purpose?
Again, we applaud MISO’s effort to bring much needed flexibility into the process, and encourage MISO to move forward quickly with this change.
Sincerely,
Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance
Savion, LLC (“Savion”) would like to thank MISO for bringing this item to the IPWG and stakeholders for discussion upon our request. As noted in prior discussions with MISO on this topic we feel there is need for flexibility on this topic. Our feedback is in response to the four bulleted items on Slide 5 of Michael Blackwell’s Presentation at the April 26 IPWG Meeting.
Item 1.
Change “from a Company Officer” to “from a Company Officer or Authorized Agent”
Item 2.
No change
Item 3.
The term ‘commercially viable’ is vague. The examples cited tend to be more restrictive than what would be needed to secure this process. Savion recommends the phrase, “IC attest and demonstrate that project has met all obligations under the GIP, GIA and any associated construction agreements.”
Item 4.
Savion holds that upgrades solely required by a single IC may be delayed if agreed to by the TO and the IC. In the case where an upgrade affects Common Use or Shared Network Upgrades, the upgrade(s) should proceed as normal, given the IC would have previously provided financial guarantees at that point.
Apex Clean Energy appreciates the opportunity to provide input on GIA Milestone Changes as presented by Mile Blackwell on 4/26/2021. MISO provided several opportunities for stakeholder discussion on the matter both during and between IPWG meetings. Apex acknowledges this effort and offers additional suggestion to the proposed options under numbered item 3 (Slide 5):
WEC Energy Group supports the proposal to allow changes to the financial and construction milestones within an executed GIA, where deemed appropriate by the Interconnection Customer (IC) and the Transmission Owner (TO) and where other ICs are not materially harmed. While existing tariff provisions provide some ability to delay GIA milestones, not all situations where a delay is appropriate are addressed with those provisions. Construction of a new generation resource is a complex process, involving multiple work streams and parties. At times, situations arise where a milestone requires modification to accommodate an unforeseen issue identified by the IC and the TO. The ability to accommodate such milestone changes will allow projects to continue forward without harm to other ICs.
The proposed criteria that MISO will apply to milestone change requests seem appropriate. We recommend that MISO include RERRA approval of a project for inclusion within rate base as a demonstration of commercial viability.
May 10, 2021
Invenergy LLC ("Invenergy") appreciates the opportunity to comment on MISO’s April 26, 2021 presentation on GIA Milestone Changes. We strongly support MISO’s proposal to add flexibility into the process. It makes perfect sense to allow GIA milestones to be altered (1) when there are no impacts to other interconnection customers; and (2) the Interconnection Customer ("IC") and Transmission Owner ("TO") agree on specific milestone changes.
Invenergy does not support a requirement that the IC be required to demonstrate that project is commercially viable (e.g. via a PPA, commercial contract) in order to have GIA milestone alternations approved. If the IC and TO agree and if there is no harm to other ICs there is no justification for MISO to withhold approval of these changes. Commercial agreements can take many weeks to complete and can be amended up to even a project COD. At a minimum, a memorandum of understanding or letter of intent between the seller and the buyer should be sufficient to demonstrate commercial viability.
Thank you.
Nicole Luckey
Vice President, Regulatory Affairs
Invenergy LLC