In the May 26 meeting of the Planning Advisory Committee (PAC), stakeholders were invited to submit comments on Generator Replacement Transfer Restrictions Tariff Changes.
Comments are due by June 8.
The TDU Sector supports MISO’s proposed exception to current transferability restrictions with the generation replacement process. This change provides potential benefits to customers, resource owners and developers by enabling more financing options for replacement projects. With the large amount of resource development activity continuing to occur, MISO should move quickly to file and implement the proposal so the benefits of the change can begin to be realized. Further, feedback on the proposal has overwhelmingly been positive. The TDU Sector thanks MISO for the efforts made in moving this proposal forward.
ReCurrent Energy appreciates MISO receiving feedback on the modifications to the Generator Replacement process. ReCurrent commends MISO staff on identifying an issue in the generator replacement process, working in close collaboration with stakeholders, and developing a durable solution that will allow for retiring assets to be replaced more efficiently. The current prohibition on transfers during the Generator Replacement functions as a meaningful barrier that unreasonably limits opportunities for existing generators to use the existing interconnection rights to bring a new resources online. Some existing resources have complex ownership structures, some are individual owner/operators with limited development experience. MISO’s proposal to lift the transfer prohibition will allow for assets to undergo replacement in a way that accommodates the litany of ownership structures and allow for MISO members to leverage the capabilities of experienced development partners.
In addition to creating a more efficient Replacement construct, MISO’s proposal to remove the transfer limitations increases opportunities for state and local governments to work with industry partners to meet clean energy goals. It also allows for C&I customers to retain agreements with existing asset owners while seeking to incorporate clean energy into usage profiles. ReCurrent also highlights the reliability benefits provided by allowing additional development partners to assist with bringing replacement generators online. Development partner expertise in the replacement process will allow for parties to work together to bring resource online potentially faster than what is expected in the current interconnection queue process. This potentially accelerated timeline can assist the MISO footprint in addressing reliability concerns caused by timing gaps between thermal resource retirements and the Definitive Planning Phase process. ReCurrent, again, thanks MISO for providing careful attention to this issue and expresses support for MISO seeking to remove the prohibition on transfers in the Generator Replacment process.