In the April 28 meeting of the Planning Advisory Committee (PAC), MISO presented draft improvements to Attachment X developed with the Interconnection Process Working Group (IPWG). Changes are required to certain elements of interconnection financial calculations and Provisional Generator Interconnection Agreement (PGIA) terms in the Tariff to better align with the fundamental, original intended designs of the queue process.
Comments are due by May 12.
The Environmental Sector appreciates the opportunity to provide comments to MISO on “Financial Impact and Provisional GIA”. This topic moved through the IPWG with several concerns and suggestions by stakeholders to address those concerns, but MISO has yet to offer any solutions. We believe now is the time to work on all issues, since they are interrelated.
In particular:
1)MISO should consider the binding decision point to irrevocably enter a PGIA (beyond which no protection exists for interconnection customers withdrawing from a PGIA) be moved from Decision Point 1 to Decision Point 2. When PGIA policies were adapted for the 3-phase process, all of the studies (power flow, dynamic stability, affected systems) were performed before Decision Point 1. Today, that has been moved to Decision Point 2, and therefore the binding decision point to irrevocably enter a PGIA should also occur at Decision Point 2.
2)Projects that enter the PGIA process in good faith based on MISO studies indicating low or no Network Upgrades, should not be overly penalized when those costs go up significantly. We understand and respect MISO’s perspective that having a PGIA withdraw impacts other projects, as does any withdrawal. However, the current approach of no penalty free withdrawal (PFW) under any circumstances for a PGIA withdrawal is unduly burdensome, especially when estimated costs increase substantially compared to initial estimates known to the interconnection customers. Therefore, doubling, or even possibly tripling (initial suggestions) the thresholds for PFW for PGIA withdrawals could be appropriate in capping the risk to PGIA customers. However, some level of protection is always needed for interconnection customers for a fair and equitable process.
These two requests are well within the scope of a Tariff edit to the PGIA process. MISO seeks to make a clarification between conflicting language in the Tariff that on one hand seems to indicate PGIA projects are permitted PFW when Network Upgrade costs increase above the prescribed threshold, and on the other hand, MISO’s stated intention is that PGIA projects put everything at risk to enter the process. The bottom line is that protections at some level are needed for the interconnection customer to maintain a fair and just process. This is an opportunity to create a much needed balance in an efficient manner.
Stakeholders appreciate the fact that if MISO is able to fulfill its intention of bringing the GIP timeline down to about a year, in practice this will largely eliminate the need for a PGIA. However, there is no guarantee that SPP affected systems or MISO TO’s will adhere to the timelines in order for the study cycle to be only a year long. In the meantime, there is still a place for the PGIA process.
We encourage MISO to work toward balancing interconnection customer needs with its own needs in assessing the financial impact of withdrawing PGIAs as the title of this topic suggests. A simple proposal for stakeholder feedback on some solutions prior to bringing this topic to the PAC would have been appreciated.