In the January 12 meeting of the Interconnection Process Working Group (IPWG) stakeholders were invited to submit feedback on the IC Option to Build revised proposal.
Comments are due by January 26, 2021.
Clean Grid Alliance Comments on Option to Build Notification Revised Proposal
Jan 26, 2021
Clean Grid Alliance appreciates MISO’s revisions to the notification of Option to Build proposal. Making an informed decision to elect or waive the right for Option to Build after transmission owner cost and schedules are available, is essential in the Option to Build process. This information is not available at Decision Point 1, and hence why a decision cannot and should not be forced on the interconnection customer at that time. However, having the optional ability to provide notification earlier in the process at Decision Point 1 for those interconnection customers whose decision does not depend on transmission owner cost or timing, can help expedite the process. MISO has proposed that the interconnection customer provide notification of the Option to Build at the Facility Study review, but there may be questions or changes based on the review, and therefore we encourage MISO to consider allowing the interconnection customer 10 business days after the Facility Study review to make a binding decision.
Sincerely,
Rhonda R. Peters, Ph.D.
Technical Consultant, Clean Grid Alliance
EDF appreciates MISO’s inclusion of past feedback provided on the Option to Build proposal. Allowing the IC to postpone the election to pursue this until after reviewing the results of the interconnection facilities study is definitely a big improvement. In light of the GIP timeline reduction initiative MISO has introduced, the general timing for the IC to make this election appears appropriate. However, one further minor improvement to consider is to allow 10 business days after the final report is posted for the binding election to be made, since it is possible some change in the cost may result from questions and responses during the review period.
NextEra Energy Resources, LLC (“NextEra”) appreciates the opportunity to provide feedback on the Option to Self-Build proposal. NextEra is supportive of the proposal as outlined by MISO and believes it is a great compromise between Interconnection Customers and the Transmission Owners. NextEra appreciates MISO hearing both sides of the argument and proposing a solution that appears to be reasonable for all parties.
Transmission Owner Sector feedback on MISO’s Interconnection Customer Option to Build Proposal
January 26, 2022
In the January 12, 2021 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on MISO’s proposal relating to timing requirements for an Interconnection Customer to elect the Option to Build qualifying Network Upgrades. The Transmission Owners (Owners or TOs) provide the following feedback for MISO’s consideration in further developing the requirements associated with this process.
The proposal outlined by MISO included a requirement for TOs will provide estimated costs associated with Option to Build in the Facility Study for IC review, but it was not clear from the presentation or the discussion at the IPWG what costs MISO is referring to, and the details regarding this aspect will need to be defined in order for the Owners to take a position on the reasonableness of MISO’s proposal.
The Owners look forward to continued discussion on these details as the process is developed further, and request that MISO refer to the Owners December 4, 2020 feedback on this topic regarding some of the details that should be considered and addressed as this effort moves forward.