In the February 10 meeting of the Planning Advisory Committee (PAC), MISO presented two improvements to the Quarterly Operating Limit (QOL) and Generator Interconnection Agreement (GIA) contingent facility processes. Stakeholders were invited to submit feedback on the two proposals including draft BPM redlines.
Comments are due by March 1.
The TDU Sector supports MISO’s proposed improvements to the QOL and GIA contingent facility processes, and offers the following suggested clarifying edits:
BPM-015
Modify MISO’s proposed addition to 6.2.9.1. to yield the following:
except that a constraint should not be considered as a limit if the LODF (Line Outage Distribution Factor) value between the overloaded element and the unfinished contingent facility is less than 20%. This LODF screening does not apply if 1. the contingent facility is an DPP study identified network upgrade from the DPP study group the resource is within, or 2. the overloaded element in QOL study, or the unfinished contingent facility, is directly connected at the generator’s POI.
Alternatively, consider eliminating MISO’s proposed changes to 6.2.9.1 and instead adding new section as indicated below, using MISO’s near-verbatim language from the presentation:
6.6.6. Annual ERIS Studies and QOL Coordination
The amount of ERIS injection that clears the Annual ERIS evaluation for the next Planning Year will not be subject to the Quarterly Operating Limits (QOL) studies for all 4 quarters of that year. Any ERIS injection that does not clear the Annual ERIS evaluation for the next Planning Year will be included in the QOL studies for all 4 quarters of that year. The customer may choose not to be included in the QOL studies if they wish to be limited by the Annual ERIS evaluation results for all 4 quarters of that year.
6.6.7. LODF Criteria for QOL and AERIS Constraints
In QOL and AERIS studies, a constraint should not limit the output of the generator if the LODF value between the overloaded line and the unfinished contingent facility is less than 20%. This screening does not apply to
1. Network Upgrades identified in the interconnection study (DPP study) for the generator, or
2. cases where either the overloaded element in QOL study, or the unfinished contingent facility, is directly connected at the generator’s POI (Point of Interconnection).
Attachment X
Modify MISO’s proposed changes to 3.8.i. to yield the following:
3.8. Identification of Contingent Facilities.
MISO identifies Contingent Facilities using the following three methods:
i. Review all transmission facilities modeled in the Interconnection System Impact Studies that are: (1) listed in Appendix A of the Transmission Provider’s Transmission Expansion Plan (MTEP) that are not yet in service, unless deemed, through engineering judgement, as not a project to that does not address an overload affected by the resource address an existing overload and not fit for an A10 study, such as, but not limited to, some aging related line renewal projects not related to associated with a baseline reliability issue, based on a review by Transmission Provider and applicable Transmission Owners; or (2) identified as Network Upgrades through the System Impact Studies for higher queued Interconnection Requests that are not yet in service. Contingent Facilities shall be identified from this list as those facilities that meet the following criteria:
March 1, 2021
Invenergy appreciates the opportunity to comment on MISO's proposal on GIA Contingent Facilities Identification and Quarterly Operating Limits as presented at the February 10, 2021 Planning Advisory Committee. MISO is right to address the problems Interconnection Customers have encountered in AERIS and QOL studies of being limited in output by constraints completely unrelated to anything in their GIA Appendix A10 list (unconstructed Contingent Facilities). We support MISO’s proposal, and encourage implementation as soon as possible to provide relief for Interconnection Customers.
Invenergy also supports MISO’s 2nd proposal to use MTEP models as the base model for QOL and AERIS studies
Thank you,
Nicole Luckey
Vice President, Regulatory Affairs
Invenergy LLC
Clean Grid Alliance Comments on Contingent Facilities/QOL
March 1, 2021
Clean Grid Alliance greatly appreciates MISO’s effort to address the problem Interconnection Customers have encountered in AERIS and QOL studies of being limited in output by constraints completely unrelated to unconstructed Contingent Facilities listed in their GIA Appendix A10 list. We support MISO’s proposal, and encourage implementation as soon as possible to provide relief for Interconnection Customers.
Sincerely,
Rhonda Peters, Ph.D.
Technical Consultant for Clean Grid Alliance
MISO Transmission Owner Sector Comments on Improvements to the Quarterly Operating Limit (QOL) and Generator Interconnection Agreement (GIA) Contingent Facility Identification Processes
March 1, 2020
As requested at the February 10, 2021 meeting of the Planning Advisory Committee (PAC), the MISO Transmission Owners (Owners) present the following feedback on improvements to the Quarterly Operating Limit (QOL) and Generator Interconnection Agreement (GIA) Contingent Facility Identification processes. The Owners support the changes presented at the March PAC meeting and appreciate MISO's continued efforts to improve these processes.
EDF Renewables, Inc. (EDFR) thanks MISO for the opportunity to provide feedback and comments related to QOL/AERIS process enhancement proposals. EDFR is supportive of the revised proposal #1; while providing minor suggestion on the recommend BPM and Tariff language through the attachment.
Additionally, EDFR encourages MISO to continue discussions on further process improvements (i.e. queue priority) pertaining to the QOL process during 2021.
EDFR appreciates MISO's responsiveness on this matter.
DTE strongly supports MISO’s efforts to minimize the uncertainties faced by generators with conditional GIAs in the QOL process. Although DTE would prefer that generators be limited only by constraints relevant to their original conditionality, because only these constraints make the interconnecting generator subject to the QOL process, MISO’s Proposal 1 is a good compromise, and DTE supports its implementation as quickly as practicable.