In the May 26 meeting of the Planning Advisory Committee (PAC), stakeholders were invited to submit comments on Fuel Change Material Modification Criteria Tariff Changes.
Comments are due by June 9.
Comments to the PAC on Fuel Change Material Modification Criteria
June 9, 2021
Clean Grid Alliance appreciates the opportunity to provide comments to MISO on Tariff Changes for Fuel Change Material Modification Criteria. We appreciate MISO’s efforts to accommodate Interconnection Customers who seek to change or add to their fuel source while in the MISO Definitive Planning Phase process and understand there is a balance to be maintained between allowing flexibility and impacting MISO staff time.
CGA supports the change to allow Surplus Interconnection requests after a project has passed Decision Point 2. This is an earlier time from today’s requirement that a GIA has been executed, and therefore allows much better planning and coordination. The flexibility this proposed change offers is appreciated.
We do have some questions regarding adding storage to wind or solar projects through the Surplus Interconnection process. Please explain if this allowed and how it will be evaluated it in regard to potential material modification around changes to fuel-based dispatch. (For example, is a 20% of nameplate dispatch for wind allowed to have an addition of storage that is dispatched at 100% of nameplate?) This question applies to all Surplus requests, but its relevancy comes front and center as Interconnection Customers will be relying solely on Surplus requests to change or add fuel sources, of which there is currently a high demand for battery storage additions. Because of this, a review by MISO of Surplus Interconnection requirements and processes, including the site control requirements, and how the Surplus process could be used to ultimately (for example) change a 200MW wind or solar that has passed Decision Point 2 to 100MW of wind or solar and 100MW of Storage, prior to negotiating the GIA, would be very helpful.
Again, we appreciate MISO’s efforts toward accommodating changes of wind and solar to hybrid projects that include battery storage, and look forward to continuing the discussion.
Sincerely,
Rhonda Peters, Ph.D.
Technical Consultant to Clean Grid Alliance
June 9, 2021
Invenergy LLC ("Invenergy") appreciates the opportunity to comment on MISO's proposed Fuel Change Material Modification Criteria Tariff changes as presented at the May 26, 2021 PAC meeting. While Invenergy does not agree that fuel change requests will create the havoc in the queue that MISO believes they will so long as those changes are assessed for material impacts on other participants in the queue, at a minimum Invenergy urges MISO to apply this new policy, which will require FERC approval, on a prospective basis. Any requests for fuel change that are currently pending or are made prior to the effective date should be evaluated by MISO in accordance with the current policy in place, as directed by FERC.
Thank you.
Nicole Luckey
Vice President, Regulatory Affairs
Invenergy LLC
MidAmerican appreciates MISO’s efforts on this topic and generally agrees with MISO’s response.
MidAmerican proposes that MISO allows generators seeking a fuel change by the generators replacement process to be studied by the project’s final Phase III model and associated network upgrades rather than the most recently completed Phase III model if the request is deemed valid prior to the negotiated COD. This would be a fair compromise to interconnection customers seeking a fuel change mid-DPP but at a disadvantage of being subject to study by a subsequently completed Phase III model in the event where their GIA is under negotiation and they were unable to begin the request until GIA execution.
In this proposal, projects seeking a request for generator replacement after the negotiated COD will remain subject to the most recently completed DPP Phase III model and associated network upgrades.