IPWG: LRTP Integration in Generator Interconnection (20220606)

EDFR appreciates MISO's thought process and consideration of the details related to the proposal to include LRTP projects in ongoing and future DPP cycles. EDFR supports MISO's proposal and BPM revisions.

Otter Tail Power Company appreciates the opportunity to provide comments on the LRTP Integration in Generator Interconnection topic. Otter Tail does not support including the LRTP projects within the DPP models until the proposed in-service date of the LRTP projects reaches the applicable model year (i.e. 5 year timeframe). The LRTP projects should be incrementally added as their in-service dates start falling within the 5-year time frame of the DPP models for the following reasons: 

1. Recent stakeholder efforts undertaken to better align the models and assumptions of the DPP process with the MTEP process would be nullified by MISO’s proposed BPM-015 redlines. This recent stakeholder effort was undertaken to ensure comparable results would be produced between the two processes. Including the LRTP projects in the DPP models sooner than the MTEP models undermines this recent effort that was taken to bring the DPP and MTEP processes together. Including the LRTP projects in DPP studies sooner than MTEP studies will create differing study results between the MTEP and DPP processes. 

2. MISO’s proposed BPM-015 redlines will create more real-time congestion on the transmission system until the LRTP projects are in-service.  Many of the LRTP projects are not expected to be in-service until the 2030 timeframe whereas new generation through the DPP process can be constructed much sooner. Adding the LRTP projects to the DPP models too soon will lead to new generators coming online through the DPP process far earlier than the LRTP projects leading to real-time congestion issues. We are currently experiencing unprecedented amounts of congestion on the transmission system and adding the LRTP projects within the DPP studies too soon will further exacerbate real-time congestion issues until the LRTP projects are in-service. 

Due to these concerns, OTP does not support the proposed BPM-015 redlines in regard to the LRTP Integration in Generator Interconnection topic.

 Thank you,

Otter Tail Power Company

National Grid  Renewables appreciates MISO involving stakeholders in this discussion and for the opportunity to comment on the proposed BPM language. MISO should make every effort to integrate LRTP lines in all tranches into upgrade solutions as soon as possible.  National Grid  renewables supports the current “case by case” interim approach in DPP cycles before it is integrated into the bench case. However, the BPM language should also reflect this interim solution, as it will continue be applicable in future LRTP tranches and the BPM should reflect this.  

National Grid  Renewables offers the following comments on the proposed redlines.

1. BPM-015 Sect. 6.1.1.1
   1. National Grid  Renewables generally supports this language as written.
2. BPM-015 Sect. 6.1.1.1.1
   1. The 90 calendar day timeframe that MISO is proposing after board approval of the LRTP Tranche is an unnecessarily long timeframe. The LRTP projects have existing models that are readily available for use in the bench cases. Therefore, MISO should utilize the same 30 calendar days that are reserved by MISO for initial modelling when integrating approved LRTP projects.

It has been MISO’s intent to reduce the Generation Interconnection Process timeline, and this approach will bring more certainty to study results. Adoption of a 30-day approval timeline will increase certainty related to approved LRTP projects and their benefits to interconnection generators.  This, in turn, will reduce guesswork, possible re-study, and the overall timeline of the Generation Interconnection Process and allow interconnection customers to make more efficient business decisions.

Pine Gate Renewables (PGR) appreciates the opportunity to comment on these proposed revisions. PGR is supportive of the revisions to Section 6.1.1.1, but is concerned that the timing proposed in Section 6.1.1.1.1 would adversely impact Interconnection Customer’s available information prior to entering the queue, potentially resulting in delay of interconnection requests or the later withdrawal of requests, both of which would negatively affect the smooth, timely processing of the interconnection queue. PGR recognizes that timing may not always align to provide Interconnection Customers with all applicable information prior to the close of the application window, but respectfully suggests that:

1. To the extent that the timing of approval could align with the application window, such could facilitate Interconnection Customer decision-making by reducing uncertainty and, thereby, reduce overall queue impacts; and
2. To the extent that Interconnection Customers can have greater certainty that LRTP projects will be included in each DPP cycle as soon as possible following its approval, impacts on Interconnection Customers and queues could be lessened.

For this reason, until timing cycles can be aligned, LTRP projects should be included in the bench case of the DPP cycle immediately following board approval without any limitations on its inclusion, e.g., regardless of the Phase of the DPP cycle. PGR notes that each DPP phase includes activities related to the updating of the model to be utilized in that phase. Accordingly, it would follow that these projects could be included at any phase of the DPP. To achieve this greater certainty and remove artificial constraints on the inclusion of LTRP projects, PGR proposes the following revisions to the proposed redline of Section 6.1.1.1.1:

Additionally, the most recent portfolio of Long Range Transmission Planning projects will be included in the bench case of the DPP cycle following board approval.

Thank you again for the opportunity to comment.

BPM-015 § 6.1.1.1: The addition of “directly interchangeable (equal or better parameters)” confuses the purpose of looking for alternative, planned projects. We are unsure how “parameters” is defined and its relevance to whether the alternate project also fixes the constraint of the original one. We would propose that the sentence be simplified to: “To mitigate a constraint, MISO will check the MTEP appendices, including reviewing Appendix A for projects beyond the MTEP 5 year out LBA dispatch bench case.” If the intent is to ensure that alternate projects do not cause additional constraints, or push issues further down a transmission path, then MISO should add language specifically to that point.

BPM-015 § 6.1.1.1.1: The “90 Calendar Days following Application Deadline” schedule for adding Long Range Transmission Planning projects into the GI study bench case is untimely. As a generation developer, we would like to know the study assumptions, including transmission, before we submit an interconnection request. These are major transmission build outs that will greatly change study results, if incorporated. With such an impact, we would request that the LRTP tranche approvals and GI modeling schedules be aligned to allow developers to understand the transmission assumptions and adjust their projects. This concern is highlighted in LRTP Tranche 2 and 3 approvals, which are targeted in December 2023 and 2024. With application deadlines continuing in the Fall/Q3, generation developers are in the dark on whether major transmission will be included at the time of their submissions.

Thank you for the opportunity to submit feedback on these topics.

1.  As part of the BPM-015 edits for LRTP Tranche 1 inclusion in MISO models, could you help clarify what the below underlined statement means?

To mitigate a constraint, MISO will check the MTEP appendices, including reviewing Appendix A for projects directly interchangeable (equal or better parameters) with the constraint beyond the MTEP 5 year out LBA dispatch bench case, and discuss with the impacted TO(s) to determine if there already exists a planned project which will alleviate the constraint. If there is no such planned or proposed project, MISO will work with the impacted TO(s) and ICs to identify a solution consistent with baseline planning solution development described in Sections 4.3.1.2 and 4.3.1.3 of BPM-020, subject to the concurrence of MISO, the TO(s) and ICs. If a project(s) resolves the constraint, and that project(s) is approved by the Board within (1) calendar year of the GIA execution or execution of an amendment thereof, then the IC will not be responsible for upgrade(s) that would resolve the constraint, but the MTEP project will be included as a GIA contingent facility. If that project(s) is not approved within one (1) calendar year of the GIA execution or execution of an amendment thereof, the IC will be responsible for those transmission upgrade(s).

2.  Apex Clean Energy supports the comments of Vestas in regard to the fact that this language needs further clarification.