In the May 25 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to send feedback on Slide 5 as well as the overall proposal. Additional comments should include feedback on the Tariff language redline document posted with meeting materials.
Comments are due by June 15.
Transmission Owner Sector Feedback on GIP Timeline Reduction Proposal and Tariff Language
June 15, 2021
In the May 25, 2021 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to send feedback on questions relating the Network Upgrade Facilities Studies and MISO’s overall proposal and the redlined Tariff language. The MISO Transmission Owners Sector (Owners or TOs) appreciate the opportunity to comment, and offer the following feedback for MISO”s consideration.
Regarding MISO’s 2 path proposal for Generator Interconnection requests that, the Owners generally support this approach, provided that Transmission Owners must also have the right to postpone GIA negotiation until the Network Upgrade Facilities Study (NUFS) is complete if one is required. However, as stated in prior TO feedback, the Owners would support the Option for the parties to begin GIA negotiations to completion of the Facilities Study, provided that, unless both parties agree to waive the Facilities Study completion requirement, sufficient time (e.g. 15 business days) is provided for review of the FS upon its completion. The Owners feel that this approach may allow the negotiation of GIAs to conclude more quickly than the approach that MISO has suggested in Section 11.2.1, while still providing the parties the opportunity consider the results of the FS in the negotiations, and prior to moving to the GIA Execution phase.
Owners have some concerns regarding the same resources working on GIAs and Facilities Studies at the same time, due to the potential for re-work or amendments to GIAs that move forward without the NUFS if one is needed. While this is somewhat manageable now, the number of projects going forward may cause a significant challenge, further complicated by the IC Self-Build and TO Self-Fund options. The changes suggested above would address these concerns, but we also suggest the following process improvements:
Some projects may have more NUs than others, and the results of more complicated Facilities Studies can be incorporated in the draft GIA on an informal basis as they are completed, with the GIA moving to the execution phase when the studies have been completed and time has been provided for review of the results as reflected in the GIA.
The Owners also reiterate our prior suggestion for the FS clock not to begin until MISO has delivered the SSA to the TO and encourage MISO to evaluate options to address IC readiness for the Owner to begin the FS once the SSA has been delivered.
TO Responses to MISO’s GIP Timeline Reduction Questions
In the May IPWG presentation, MISO noted that stakeholder feedback continues to state that some aspects of the NUFS reports are critical (for both IC’s and TOs) to have prior to completing the GIA negotiation process (i.e. the feasibility of the solution, and the construction schedules, and updated costs), and MISO has requested feedback on the following:
1) Can a preliminary feasibility study be performed on the final NU list (For each TO) that’s proposed as part of the Phase III SIS report?
MISO noted that they are proposing to extend the Phase III timeline by an additional 20 calendar days, suggesting that Phase III should be able to serve as the opportunity for TOs to determine if the NUs being provided are feasible or not. As MISO also noted, kicking off the NUFS as early as possible should expedite this process.
However, regarding the potential for a Preliminary Feasibility Study to determine the “feasibility” portion of the FS, the Owners clarify that the preliminary Feasibility Study includes only costs. More than a desk-top analysis is needed to evaluate the actual feasibility of solutions identified in the SIS. Determining the feasibility of these solutions, along with cost and schedule, is the purpose of the FS. Therefore, the Owners would rather not provide a preliminary Feasibility Study or attempt to advance sections of the Facility Study, as this would create undue stress with little benefit. Providing a budgetary/generic schedule with the DPP III cost estimate would be a better option; this could include a basic estimate of costs and schedule for the facilities that are likely to be needed based on items such as structures and line miles, and could be provided for general information only, with the understanding that this information would not be used in any agreements and that the final FS is needed for the agreements.
2) Can high-level construction schedules be shared with the study group when the final list of Phase III mitigations/NUs are provided by TOs? This can ensure that customers have some initial guidance on how long with may be conditional on certain NUs.
As noted above, a general schedule could potentially be included in the Preliminary FS for information only, based on the proposed solutions, however, outage schedules are a large part of construction schedules and this information is not known until towards the end of the FS, once the mitigation plan has been determined to be feasible.
3) Can aspects of the TO NUFS process be re-arranged to expedite it? So that the critical information (That IC’s need during GIA Negotiations) is figured out first and then shared earlier on in the process (As compared to waiting for the final NUFS report to come out with that info).
No, the TO NUFS process cannot be re-arranged because the critical information needed for all parties to execute a GIA are the project cost and schedule, which is what the FS determines. Technical details of the interactions between the Interconnection Customer’s Interconnection Facilities and NUs are needed to finalize the mitigation plan and construction schedule, as well as necessary land purchases, etc.
MISO may be able to accelerate the completion of these studies by authorizing the release of FS funds earlier in the process. The FS cannot be done faster, but it can be done sooner in the GIP.
4) MISO would also like to be given examples of where costs have dramatically shifted between the Phase III SIS report estimates and NUFS report estimates (for particular network upgrade projects).
Given the limited number of Interconnection projects that have executed a GIA when Network Upgrades have been identified, it may be more productive for MISO to gather this information for the footprint for further discussion and evaluation. That said, the past may not be a good indicator of the future in this case, as the potential for Network Upgrades to be needed increases as transmission system capacity is consumed and the queue grows.
The Owners also recommend clarifying edits to Proposed Section 7.3.1:
In addition, Interconnection Customer may request that the Transmission Provider initiate the Interconnection Facilities Study be initiated during Definitive Planning Phase I. If Interconnection Customer, Transmission Owner, and Transmission Provider agree that such Interconnection Facility Study should be performed during Definitive Planning Phase I, Transmission Provider shall begin the Interconnection Facilities Study during Definitive Planning Phase I.
Savion, LLC (“Savion”) would like to thank MISO for bringing this item to stakeholders for discussion. In response to MISO’s request for specific examples where costs have drastically increased from the Phase III SIS report estimates to completion of the Network Upgrades Facilities Studies we can point to multiple examples. The most recent example affected a project we had as part of the DPP-2018-ARP study group where costs increased by several million dollars in total. These were significant enough that the penalty free withdrawal provisions would have applied should we have chosen to go that route. Due to the uncertainty we face and real world project examples we can point to emphases why it’s important to have the Network Upgrade Facilities Studies complete prior to entering GIA negotiations. Further details are available for discussion in a non-public venue.
While Savion appreciates MISO’s addition of an alternate patch to allow for completion of the Network Upgrade Facilities Studies prior to commencing GIA negotiations we have questions and concerns with how the two paths will tie together being on different timelines. The primary question and concern is in relation to MPFCA’s. How will MISO determine the appropriate schedules for negotiating these types of agreements? If IC’s that share in these agreements choose each path when will MISO issue them for negotiation? How does MISO see addressing the timing differences.
Lastly we’d also like to note that we have seen delays of various forms during GIA negotiations which include things from TO’s failing to provide comments on time as requested by MISO, to continued schedule conflicts from all parties requiring meetings be rescheduled. While these things can be managed it’s important to note that if they are not addressed MISO’s proposed timeline reductions will only cause more problems