IPWG: Provisional GIA Construct (20210921)

ITC appreciates the opportunity to submit feedback on the PGIA construct proposal and has the following comments:

ITC does not support the proposed change identified by MISO for the Provisional GIA process.  ITC believes that the current process serves its goal of providing a mechanism for projects that are basically ready to build in the queue thus reducing the burden for them of waiting through the entire DPP process to connect yet allowing for a small off ramp should something unforeseen appear in DP1.  For other interconnection projects that are not quite as ready to enter the existing PGIA process but want to make a step in that direction, the existing Engineering and Procurement Agreement allows these projects to determine just how close to the PGIA process they would like to be.  This can even be done in steps with the TO thus moving their project along but allowing them to determine when and how much risk they want to take on.  ITC believes these two existing processes provide sufficient flexibility for Interconnection Customers without placing additional burden on Transmission Owners.  It is ITC’s opinion that moving to the proposed PGIA construct would create additional burden on Transmission Owners by allowing additional Interconnection Customers who may not be ready to go to enter PGIA’s with the ability to utilize the risk free off ramp to a standard DPP up through DP2.

The work performed by the Transmission Owners for these Interconnection Customers who have entered a PGIA when not ready is unnecessary additional work.

Clean Grid Alliance Comments on Provisional GIA Construct
Oct 12, 2021 

Clean Grid Alliance appreciates the opportunity to provide comments to MISO on Provisional GIA Construct. We appreciate MISO’s efforts to reduce the GIA timeline and are hopeful this effort will be successful, but cannot make that assumption given the billions of dollars at stake if delays continue to occur. Additionally, the GIA timeline reduction proposal will not be fully implemented until the 2024 study group so the full benefits will not be realized for 3-4 years out. There is still a need for an accelerated process to reach GIA prior to studies being complete, to hedge against potential study delays and backlog.  IC’s requesting a PGIA need a safety net when project timetables are compressed due to off-taker demand, including the needs of MISO’s utilities to decarbonization over near and short-term horizons.

We encourage MISO to consider a high end financial cap that balances the need for a higher risk process to request a PGIA, but allows for projects with minimal upgrades and a need to be operational sooner than the study group timing is able to reach. We fully support MISO’s position that projects should take on higher risk for the PGIA process, but also that some cap, even as high as 200% of costs, would help protect projects from unexpected and unreasonable increases.

Thank you for considering this feedback, 

Sincerely,

Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance

Ameren believes the current PGIA construct provides the appropriate balance of risk for the Interconnection Customer that elects to pursue this expedited option.  As the Central region continues to experience an uptick in interconnection requests, allowing the Interconnection Customer the option to revert to the standard DPP process at Decision Point II could derail the effectiveness of the PGIA process and potentially result in adverse outcomes for the Transmission Owner. In light of the foregoing, we do not support the proposal for the Interconnection Customer to revert to the standard DPP process at Decision Point II.

EDFR supports MISO's existing process as being sufficient to deal with requests for Provisional GIAs. We do not support making modifications to the GIP to provide for any additional time in which ICs may request Provisional GIAs nor do we support revising the milestone refund structure to provide for separate milestone refundability mechanisms for projects that request PGIAs.

this is one area where interconnection customers can choose to use the existing process instead of pursuing additional optionality via PGIAs - any such effort will vastly exceed the potential benefit, especially in light of how MISO has improved their current study processing timelines and the future reduction in that time.