PAC: GI Site Control Deadline (20210210)

March 1, 2021

Invenergy appreciates the opportunity to provide feedback on the Site Control Deadline Precision proposal presented at the February, 10, 2021 Planning Advisory Committee meeting.  Invenergy very much appreciates MISO's decision to implement a site control deadline and retain it even if the schedule accelerates.  Developers very carefully plan their land acquisition efforts and this helps to assure that projects can still participate in a given DPP instead of waiting until the next cycle.  The same need for precision applies if schedules slip significantly.  Procuring leases for land is extremely expensive.  If schedules slip a few weeks this is not an issue.  If schedules slip 6 months to a year, this is a real and substantial cost to developers for something that technically is not required until 90 days prior to studies starting.  Invenergy is concerned that the current proposal, which would keep the site control deadline the same no matter how long MISO's study schedule slips, penalizes developers, costing them potentially millions of dollars at no fault of their own.

Invenergy suggests that, if delays are 3 months or longer, that MISO push out the site control deadline to a new date.

Thank you,

Nicole Luckey

Vice President, Regulatory Affairs

Invenergy LLC

Clean Grid Alliance Comments on Site Control GI Continuous Improvement

March 1, 2021

Clean Grid Alliance (CGA) greatly appreciates MISO’s responsiveness to Interconnection Customer concerns regarding MISO moving up (shortening) the timeline for site control. As commented previously, site control acquisition has many moving and unpredictable parts requiring months of advance planning. It is extremely difficult to speed this process up with very short advance notice. MISO’s solution to maintain a fixed date and not move up the site control deadline helps prevent future widespread panic among interconnection customers who in spite of the most diligent efforts, could be faced with a nearly impossible situation in speeding up the process on short notice. 

CGA would also like to request that MISO reconsider its position regarding when study deadlines slip, that MISO does not plan to move back the site control deadline, but to also keep it fixed in this circumstance. Obtaining site control requires monthly payments that can be extremely costly in some locations. The interconnection process is already several years long where interconnection customers are paying large sums of money monthly to hold land, but not able to obtain any return on that investment while going through the (often years-long) MISO queue process. Additionally, in exchange for MISO not moving up the site control deadline date, interconnection customers are being asked to accept a higher risk as a tradeoff because study kick-off (when $2k/MW becomes “at risk”) can pass before MISO certifies the site control as valid. This is already a significant trade-off. Allowing site control deadlines to be pushed back when study kick off is pushed back, is one way that MISO can alleviate an additional burden on the interconnection customer. 

We sincerely appreciate MISO’s efforts to address concerns about site control deadlines being moved up, and look forward to further discussion. 

Thank you,

Rhonda Peters, Ph.D.

Technical Consultant for Clean Grid Alliance

MISO's proposal is mostly acceptable, though there are a couple of revisions that could be useful:

• if for some reason the DPP start date is advanced, MISO should ensure language in BPM/Tariff would not put M2 50% at risk prior to informing the IC that their site control submission is complete or not if that review is not complete by the time the DPP1 study begins.
• MISO should make every attempt to indicate realistic study start dates prior to the application deadline so that start dates do not need to advance.