In the March 16 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on the Option to Build Draft Tariff language. Please provide feedback by March 30.
WPPI Energy offers suggested clarifying edits to the proposed language in red-line Word document submitted separately.
NextEra Energy Resources, LLC (“NextEra”) appreciates the opportunity to comment on the Option to build proposal. NextEra appreciates the ability to allow for a deferral on the election of the option to build until after the ICIF review. Allowing for the deferral until the ICIF review and requiring the Transmission Owner to provide cost estimates in the Facility Study allows for the Interconnection Customer to have a better idea on the total costs so they can make a well-informed decision when making their election.
Transmission Owners Sector Feedback on Interconnection Customer Option to Build
March 30, 2021
In the March 16, 2021 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on the Option to Build Draft Tariff language. The following feedback is offered by the MISO Transmission Owners Sector.
The MISO Transmission Owners appreciate the opportunity to provide feedback on MISO’s Option to Build Draft Tariff language. In general, the TOs support MISO proposal to clarify in the Tariff a binding point in time when the IC must elect the Option to Build. However, the Owners suggest making the following improvements before the proposal, including Tariff language, is finalized:
1. Interconnection Customers have the Option to Build Stand Alone Transmission Owner Interconnection Facilities and Stand-Alone Network Upgrades. MISO’s proposal does not appear to be applicable to the IC Option to Build option for Stand-Alone Network Upgrades. MISO’s proposal allows the IC to elect the Option to Build 10 days after the Interconnection Customer FS review does not account for the IC right to elect this option for Stand Alone Network Upgrades not identified until Phase III, needed for deliverability as opposed to interconnection. Given that the IC has the right to elect to build these facilities, MISO’s proposal should also address the appropriate point in time for the IC to elect the Option to Build these Upgrades. MISO should consider the impacts under their proposal with respect to the associated agreement timeline. If the IC elects to self-perform and makes this after the Facility Study in Phase III, it will delay the negotiation of these agreements.
2. MISO’s GIP uses confusing terminology. Confusion may arise when stakeholders don’t have a consistent understanding of the terminology associated with the various study components for example: the “ICIF FS” is performed in Phase 2, but in this study the TO is studying the TOIF, TOs never study ICIF. The terminology used to describe this study may cause confusion in the facilities being referenced, relative to the facilities that the IC is eligible to build.
3. An IC should be able to rescind the Option to Build election through the GIA negotiation, provided the TO and IC both agree to accept the change in election. Many TOs desire to construct all facilities they will own but agree that ICs have the unilateral Option to Build Transmission Owner Interconnection Facilities and Stand-Alone Network Upgrades. GIA negotiations are generally the first venue where the TO and IC can discuss facilities to be constructed under the GIA. If during those discussions, the IC determines they no longer desire to elect to self-build, the IC should be allowed to rescind its election upon mutual agreement with the TO.
On the proposal generally, the TOs raise the following concerns, which should be addressed in MISO’s proposed tariff language:
1. TO Cost Estimates for Oversight: TO cost estimates for oversight will vary based on the scope of what the IC elects to build, the IC’s familiarity with the TO’s specifications, the IC’s familiarity with state and county requirements, thus the IC’s project schedule and should not be considered binding.
2. IC Project Cost Estimate: The requirement for an IC to develop a cost estimate for projects within 10 days of receiving the facility requirements from the TO may not be enough time for the IC to develop a quality facility design.
3. TO Opportunity to Review and Comment: The TO should have the opportunity to review and comment on the IC’s scope and estimate after the IC review period.
4. IC Right to Begin Work/Incur Costs: Notification of the intent to exercise the Option to Build does not provide any rights to the IC to begin work/incur costs prior to a GIA. In cases where the TO intends to self-fund and the IC desires to build eligible facilities, cost motivation exists for ICs to begin construction activities prior to having an agreement in place, in order to avoid inclusion of pre-GIA costs (for example site development, permitting, land acquisition, material purchase, etc.) in Stand Alone NU costs, which are eligible for TO funding. The IC’s election of the Option to Build does not diminish these rights. Ultimately TO funding and the IC Option to Build are only valid after elected under an executed GIA. Preliminary work on Option to Build/Stand Alone facilities can only occur if the IC and TO have an agreement in place (an Engineering and Procurement Agreement) to provide for such work.
Clean Grid Alliance Comments on Option to Build Notification
March 30, 2021
Clean Grid Alliance appreciates the opportunity to provide comments on MISO’s March IPWG presentation regarding “Option to Build” notification. We appreciate MISO’s efforts in proposing a solution that strikes a balance between Transmission Owner and Generator Interconnection Customer needs. We particularly appreciate that Generator Interconnection Customers are able to make a decision on “Option to Build” after reviewing the Facilities Study information, but if they know in advance at Decision Point 1, regardless of Facilities Study results that they will be waiving their right, they can optionally provide notice at that time. We support the proposal presented at the March IPWG.
Sincerely,
Rhonda Peters, Ph.D.
Consultant for Clean Grid Alliance