In the April 26 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to send feedback on the Generator Interconnection Procedure (GIP) timeline reduction proposal and accompanying Attachment X changes.
Comments are due by May 12.
Transmission Owners Sector Feedback on GIP Timeline Reduction and Attachment X Revisions
May 12, 2021
In the April 26, 2021 meeting of the Interconnection Process Working Group (IPWG), MISO invited stakeholders to submit feedback on the Generator Interconnection Procedure (GIP) timeline reduction proposal and related changes to Attachment X of MISO’s tariff. Regarding the Transmission Owners Sector (Owners or TOs) feedback provided below, the Owners Sector is generally comprised of integrated utilities that are also Load Serving Entities and Interconnection Customers, and the comments below on MISO’s proposal represent this broad perspective, which we provide for MISO’s consideration.
GIA Tender, Negotiation and Execution
The Owners continue to believe that MISO’s proposal to decouple the Network Upgrade Facility Study from the GIA by initiating the timing deadlines for GIA execution prior to completion of Network Upgrade Facilities Studies (NU FS) would create significant uncertainty in the interconnection study process. While MISO’s latest proposal includes some provisions that could, under some circumstances, allow the NU FS to be completed in time for GIA negotiations, completion of these studies is not guaranteed prior to the conclusion of GIA Negotiation or Execution timelines.
System Impact Studies (SIS) do not provide sufficient certainty in the scope of necessary Network Upgrades because they provide only planning level estimates of the facilities needed, as they are based on a desktop exercise only, the solutions identified in the SIS may not be feasible if the project proceeds to a Facilities Study (FS). Requiring an IC to execute a GIA before the facilities necessary for the interconnection may result in additional queue “churn” due to cancellation of GIAs following IC execution or unexecuted filing at FERC and more requests for unexecuted filing, which further increases the uncertainty associated with these agreements. These concerns are exacerbated by MISO’s lack of a structured GIA Amendment process, which tends to allow requests for amendment to linger.
While MISO has indicated that the NU FS results and the planning level cost estimates included in previous SIS reports have not changed much, very few ICs have historically moved forward when significant Network Upgrades have been identified, though this trend appears to be changing.
A possible solution would be to extend the signature period to four weeks after the NU FS is completed if it is not completed within 28 days of the expiration of the GIA Execution period. This would allow for the parties to adjust any milestones as appropriate or to file the GIA unexecuted if the changes were too significant to accomplish within the four-week period.
Facilities Study Timing
The Owners also have concerns with provisions proposed by MISO regarding the Facilities Study timing requirements associated with the delivery of the Facilities Study by the Transmission Owners.
Proposed Section 7.3.2 indicates that the TO has a firm “90 days” to deliver the FS, but Section 7.3.4 provides for “best efforts” to deliver the study in 90 days. It is not clear whether MISO intended for the 90-day FS delivery requirement to be firm, so clarification is needed; however, the Owners cannot agree to a firm deadline to deliver these studies, and ask that MISO use reasonable efforts” consistently. Potential drivers of FS delay include but are not limited to:
To address these issues, the 90 days provided for the completion of the Facilities Study should not begin until the MISO and IC have delivered everything the Owner needs to perform the study (for example, the Shared Services Agreement and all of the information needed to accurately model the project). In order to avoid further study delays MISO should also consider including provisions that would address what happens if the IC is not prepared to move forward when the FS is supposed to begin.
Other potential drivers of FS delays that should be considered include:
Negotiation, Execution and Filing Timelines: Sections 11.2 and 11.3
Finally, we ask that MISO consider the range of approval processes required by Transmission Owners, which can vary depending on the cost of the upgrades identified in Facilities Studies, and that the proposed timeframe for GIA execution by both parties may not be sufficient. In order to avoid the unnecessary filing of unexecuted GIAs with FERC, the tariff language should include a reference to the use of” best efforts” to meet the targeted timelines.
The Owners thank MISO for the opportunity to comment.
EDFR appreciates the opportunity to comment and is supportive MISO's GIP Timeline Reduction proposal presented at the April 26 Interconnection Process Working Group. We encourage MISO to continue identifying process improvement opportunities, collaborate and share the lessons learned with the neighboring systems.
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.
However, it is a great concern that the time savings proposed through process improvements on MISO studies will not produce the intended time savings. If true the more aggressive timeline will only increase the risk of failure to meet the IC need for process certainty.
We also have significant concerns with MISO’s proposal to start GIA negotiations prior to completion of the Network Upgrade Facility Study (“NUFS”). We have seen significant cost deviations and schedule impacts from SIS estimates to NUFS estimates amongst other issues and having that information for GIA negotiations is critical. If any new upgrades are identified in DPP Phase III and it takes 90 Calendar days to complete the NUFS upon completion of the Phase III SIS then the negotiation period would be over according the proposed timelines. How does MISO plan to address this issue? If the NUFS is allowed to complete it would delay the GIA timelines. If MISO doesn’t the negotiation period would be over and the GIA would be out for execution without having all the necessary information included.
Further, Savion is concerned that much of the shortened timeline comes from the requirement that IC meets shorter deadlines to meet hastened milestones.
May 11, 2021
Invenergy LLC ("Invenergy") appreciates the opportunity to provide comments on MISO's GIP Timeline Reduction and Attachment X proposal presented at the April 26 Interconnection Process Working Group.
Invenergy would reiterate that understanding not only the cost, but the expected construction schedule for network upgrades, is critical to a project's commercial strategy. While construction timing for an IC's own interconnection facilities is clearly most important, the schedule for network upgrades to be completed will tell a developer whether their project will be operationally limited and whether it might make more sense to push out a project COD (to an appropriate date consistent with what is allowed by the MISO tariff) to better align with when those upgrades will be complete. Forcing an IC to negotiate a GIA without having access to this critical schedule information is not good policy and will have diminishing returns. While Invenergy is generally supportive of MISO's efforts to reduce the GIP timeline, the schedule should only be accelerated where stakeholders are not sacrificing such information.
Thank you.
Nicole Luckey
Vice President, Regulatory Affairs
Invenergy LLC
Clean Grid Alliance Comments on GIP Timeline Reduction and Attachment X
Interconnection Process Working Group
May 10, 2021
Clean Grid Alliance appreciates the opportunity to provide comments on the GIP Timeline Reduction and Attachment X discussion topic at the April IPWG. We continue to have concerns about the shortened timeline having negative impacts on the interconnection customer’s ability to choose a COD schedule at GIA negotiation and execution that will not need to be changed later. As discussed during the meeting and provided in our earlier comments, Network Upgrades on the system can impact a project’s COD and without information on the construction schedule of those upgrades, an interconnection customer could be forced to make a decision that causes it financial harm. Construction timing of the ICIF Network Upgrades in advance of GIA negotiation is clearly the most critical information to have in setting the COD date/schedule, but other system Network Upgrades can cause a project to have significantly limited output to the point where financially, it makes more sense to wait to reach commercial operation until those Network Upgrade are in service. We strongly encourage MISO to ensure that one way or another the interconnection customer has both the schedule and cost information of all Network Upgrades prior to GIA negotiations. Changing the COD and milestones after GIA execution is a hassle for everyone, and in many cases, may not even be possible. It is important that MISO not prevent the interconnection customer from having the best available information at the time of GIA negotiation to base their COD schedule on.
Sincerely,
Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance
DTE thanks MISO for the opportunity to provide feedback on this topic. DTE is highly supportive of reducing the overall GIP timeline, but feels the model development step is critical.
GRE comments from April 26, 2021 IPWG Meeting
Great River Energy appreciates the opportunity to provide comments to MISO on the following IPWG item:
“GIP Timeline Reduction and Attachment X”
GRE has some concerns with the reduction in the GIP timeline in respect to GRE possibly self funding these projects.
With the example #1 in the IPWG slide deck from 4/26 (shortened DPP example #1- parties request early GIA tender) there is a possibility that the NUFS would not be complete prior to the end of the GIA negotiation. If the NUFS is not complete we do not know what the final dollar amount will be needed to fund the projects and we cannot go to the GRE board to ask for approval without knowing how much we are asking for.
In addition, we need to have 2 board meetings before a project can be approved. The first meeting you bring all information to the board and they will vote to approve/reject at the second meeting. Under the best case scenario we need ~60 days to get the information put together and presented to the board. Worst case scenario we need ~85-90 days.
If we are not self funding this is less of an issue because we can take the information to the board with planning level estimates. Since the project would be reimbursable we are typically asking the board for permission to enter into the agreement with an estimate of total spend.
Firstly, all new proposals look great.
One thing I think needs to be given more attention to however, are Affected Systems Study delays. They hold back the entire queue cycle, which harms projects and TOs alike. Affected Systems need to be given stricter deadlines. Perhaps an option would be to have them pay for any network upgrade they fail to identify within a given deadline.