MISO is requesting feedback on posted LRTP integration options for Interconnection Requests.
Please provide feedback by April 29, 2022.
Great River Energy supports integrating LTRP in upcoming DPP cycles, only after the LRTP projects have preliminary state regulatory approvals in place as that need and siting processes could result in a different routes or project configurations. In addition, Incorporating the LRTP upgrades early would likely result in new conditional generator interconnections, resulting in higher amounts of congestion since the gap between when the generation goes into service and when the LRTP projects go into service will be five to ten years or more, as in the case of Cardinal to Hickory Creek 345 kV line.
Clean Grid Alliance Comments the on LRTP Integration Options for Interconnection Studies
April 29, 2022
Clean Grid Alliance appreciates the opportunity to provide comments on Integration of Long Range Transmission Plan Options for Interconnection Studies. LRTP transmission can help generation projects to interconnect that otherwise would not have been able to, but it can also have unintended negative consequences for operating generators and generation interconnection projects not dependent on LRTP. Those impacts must be considered and accounted for. Due to the diversity of our membership, CGA will leave comments on the three options to our members, while offering suggestions that apply regardless of which study group MISO implements LRTP into.
Generator interconnection projects that depend on LRTP transmission (and other transmission and Network Upgrades) are considered “conditional” until all of the required transmission and Network Upgrades are constructed. Conditional projects are subject to Quarterly Operating Limits, Annual ERIS studies, and (where applicable) Annual NRIS studies, all of which can limit the generator’s output.
Generator interconnection projects not dependent on LRTP do not want to become conditional and hence be subjected to restricted operating output simply due to proximity to LRTP transmission lines, given that power flows through the path of least of resistance. The sooner LRTP lines are fully integrated into generator interconnection study models, the sooner the potential for this to occur.
Additionally, conditional projects that depended on LRTP lines can come online prior to those lines being built and contributed significant congestion while conditional, even if they are not output limited for reliability purposes. If LRTP lines take 7-10 years to construct, the impact of conditional projects to nearby operating projects with full interconnection rights can be very significant.
MISO’s integration of LRTP into generator interconnection studies must carefully balance the three conditions noted above to minimize negative impacts to the queue and operating projects while allowing projects that depend on LRTP lines to move forward. Consideration of differences between regions within a study cycle may be needed as well as consideration of the impact on congestion from LRTP projects allowed to interconnect conditionally prior to in-service dates of LRTP transmission lines.
We sincerely appreciate MISOs efforts to consider stakeholder input on the integration of LRTP projects in interconnection studies.
Pine Gate Renewables Feedback on LRTP integration options for Interconnection Requests
April 29, 2022
Pine Gate Renewables (“PGR”) appreciates the opportunity to provide comments on the Integration of Long-Range Transmission Plan Options for Interconnection Requests. For the 2020 cycle and prior cycles, we support Option 1. For the 2021 cycle and beyond, we support Option 3 without additional consideration.
1) Integrating the LRTP in the upcoming 2022 cycle provides the following benefits:
a) Reduces the Quarterly Operating Limit Study scope and burden on MISO and undue hardship on generators;
b) Significantly increases certainty within the MISO market;
c) Creates a more comprehensive queue window with higher project viability (financially, regulatory, etc.); and
d) Gives MISO stakeholders more time to develop and implement their fleet turnover plan.
Simply put, it best achieves the goal of minimizing negative impacts while allowing projects that depend on LRTP lines to move forward.
2) Option 2 (2020 cycle) and Option 1 (2021) cycle both have the effect of delaying studies. MISO currently has a backlogged queue and hasn’t finished the several studies dating back to 2019. Delaying more studies, as would result from implementation of Option 2 (2020 cycle) and Option 1 (2021 cycle), will only add to the study delay/backlog.
3) PGR supports case-by-case analysis pursuant to BPM-015-r23, pg. 50. By utilizing the case-by-case evaluation and leveraging the existing time periods and process already approved by Stakeholders, generators in both the 2020 & 2021 DPP Cycles will be treated equitably and comparably. Since the established process initiates upon the signing of the (Generator Interconnection Agreement) GIA or an amendment, use of the existing timeline and process will allow both the 2020 and 2021 DPP cycles to mitigate the potential for upgrade responsibility while also reducing the likelihood for confusion, ambiguity, or later challenges to the implementation of LRTP Integration in Generation Interconnection.
MidAmerican Energy Company (MEC) supports Option 3 as presented in the April 11th, 2022 IPWG to integrate LRTP starting with the 2022 cycle.
Starting with the 2022 cycle is the most clean and fair option to all interconnection customers because there will be more information available on the estimated construction schedule of the Tranche 1 LRTPs and the determination to include the Tranche 1 LRTPs will be known prior to DPP start. Additionally, the projected in-service dates of many Tranche 1 LRTP projects would better align with the MTEP22 5-year out models that will be used as the starting point for the 2022 cycle system impact study.
DTE appreciates the opportunity to provide feedback to MISO on the topic of integrating LRTP projects into the generation interconnection process. Integrating the scope of these projects into transmission modeling sooner rather than later will be key in ensuring that transmission upgrades related to generator interconnection projects are right sized and cost efficient.
After reviewing the various options that MISO has laid out for each cycle DTE would suggest that projects that are in the 2020 cycle and prior and are expected to be in Phase 3 by July 2022 be integrated on a case-by-case basis for directly compatible upgrades. Because of the stage that these projects are in we deem this the most efficient approach to integration. For those projects that are in Phase 2 of the 2020 cycle that are expected to be delayed and would not complete until after LRTP Tranche 1 approval, DTE would support MISO’s option 2 which is to incorporate the LRTP projects in the base case for Phase 3. With this option we do however question the need to pause Phase 2 in this scenario. If the LRTP projects would be included in the base case for Phase 3 we see no need to pause Phase 2.
Lastly, for 2021 cycle projects that are already in Phase 1 and delayed from higher-queued Affected System delays DTE supports option 2 which is to proceed with Phase 1 once delays are resolved and then integrate LRTP in Phase 2.
Enel appreciates this opportunity to provide feedback on LRTP Integration Options for Interconnection Requests. Enel supports Option 1 for DPP 2020 and Option 3 for DPP 2021. Enel believes that these options will prevent queue delays, provide a clean transition, and are best aligned with existing MISO policies.
Enel supports maintaining the current BPM-015-r23 policy of evaluating MTEP projects approved within one year of a signed GIA. This one year policy is a well-established process with proven benefits. Interconnection Customers benefit through the inclusion of planned transmission upgrades in late stages with a high degree of certainty. Extending the policy to two years would mean including upgrades that are less certain and in earlier stages. The timing and certainty misalignment could lead to an increase in projects seeking Conditional GIAs, which is contrary to the original intent of this policy -- allowing Interconnection Customers and Transmission Owners to proceed with realistic near-term assumptions regarding constraint relief.
Additionally, allowing a single queue cluster (DPP 2021) to benefit from a two year extension of this policy is unfair to future queues. If this policy is extended to two years, it must be permanently extended to two years for all queues going forward.
WEC Energy Group recommends that MISO apply the LRTP Tranche 1 portfolio to future queues only. The targeted 2030 in-service dates for the LRTP projects within the Tranche 1 portfolio are well outside of the current 5 year out model used for DPP studies. Applying the LRTP projects in early queues, either in whole or on a case-by-case basis, will result in a large number of GIAs that are conditional for years. Conditional GIAs, while subject to annual ERIS and QOL studies, often create significant congestion that severely limit the value of not only the resource with the conditional GIA, but neighboring non-conditional resources as well. At the earliest, MISO should apply Tranche 1 to the 2022 queue but also consider the advantages of not applying Tranche 1 to the DPP studies until we are within 5 or 6 years of the LRTP in-service dates.
The LRTP Tranche 1 projects represent an important first step in the necessary expansion of transmission to unlock greater clean energy development within the MISO footprint. AES looks forward to the Boards approval of these vital investments. AES appreciates the opportunity to provide feedback on how to integrate the LRTP projects into Generation Interconnection Process.
AES agrees with MISO’s proposal to apply existing BPM-015 language to interconnection projects in the 2020 cycle and prior cycles that would integrate the LRTP projects on a case-by-case basis to mitigate identified network upgrades, allowing Interconnection Customers to enter into conditional GIAs.
For 2020 study cycles that have yet to reach Phase 2 by the time of the LRTP Tranche 1 approval, AES believes that MISO should not include the LRTP projects in the base case and consider the LRTP projects on a case-by-case basis during GIA negations. This option is preferred because it wouldn’t lead to any further delays in the interconnection study process. It would also give Interconnection Customers flexibility to determine whether they would choose to sign conditional GIAs or invest in the necessary upgrades to avoid potential injection limitations.
For any 2021 cycle projects, AES believes that MISO should pursue Option 1 to fully integrate and incorporate the LRTP projects into the base cases in Phase 1. Since Phase 1 is already delayed until June, waiting an additional month to incorporate the LRTP projects into the base cases is preferable than having more variable Phase 1 and Phase 2 study results. Delaying Phase 1 until the LRTP projects can be incorporated into the base cases would give developers a clearer understanding of project costs and would minimize the need for later stage restudies and uncertainty which could create greater delays in the future under other alternatives being considered. MISO should provide flexibility to Interconnection Customers to opt out of LRTP projects conditionality on a case-by-case basis, allowing Interconnection Customers to fund certain Network Upgrades to mitigate identified constraints if the Interconnection Customer chooses to.
Thank you for offering EDF Renewables (EDFR) and other effected parties the opportunity to comment on the key and critical issue of the approach to modeling bulk transmission projects. EDFR believes that inclusion of LRTP projects after they are approved by the MISO Board of Directors should be done in an intelligent and purposeful way. The approach should be informed by lessons learned from MISO MVP transmission projects experiences, recent operational situations, and market results and activities. EDFR believes that premature inclusion of LRTP bulk transmission projects could misuse and devalue benefits available from renewable resources through hasty interconnection and commercial operation resulting in increased curtailment and congestion. The over reliance on contingent transmission and subjugation to Quarterly Operating Limits (QOLs), curtailment, and congestion should be better managed and supported by MISO, transmission owners, and interconnecting resources.
The energy industry presently faces, and will continue to, the spilling of renewable resources energy from curtailment, this is an unrecoverable societal loss. The excess congestion that is being presently realized will continue and be exacerbated if we do not better optimize needed upgrades, commercialization timing, and DPP study model inclusion of planned bulk transmission expansion and upgrades.
This rampant congestion, that could be better managed, is hurting load and feels punitive to some resources. Therefore, it is imperative that appropriate and correct upgrades are identified during interconnection process. It is equally important that bulk transmission upgrades and expansions are not irresponsibly included in models and evaluations, resulting in identification as contingent facilities, which leads to the untimely commercialization of resources.
The commercialization and operation of resources should be appropriately managed with the timing of requirements to optimize full unconditional operation, including bulk transmission upgrades such as LRTP transmission projects. It makes the most logical sense to stager the inclusion of bulk transmission upgrades into generation interconnection DPP process models when they are within five years of estimated energization, an OPTION 4. If this itemization approach proves to be problematic or untenable it is preferred that the inclusion of LRTP projects in totality be appropriately delayed coinciding to within a four- or five-year estimate of the energization of first mover LRTP projects, e.g., if first mover LRTP projects are expected to be energized in 2026, then include LRTP in 2022 DPP cycle.
EDF Renewables rank of the three options offered by MISO for integrating LRTP with 2021 cycle:
EDF Renewables Ranking of three Options MISO offered at Interconnection Process Working Group (IPWG) on April 11, 2022, see IPWG Item 05. Find the following options ranked in numerical order with some high-level logic:
Xcel Energy appreciates the opportunity to comment on the LRTP Integration Options for Interconnection Requests. Xcel Energy supports Option 3, integrate LRTP only for upcoming 2022 DPP cycle. Xcel Energy does not believe that Options 1 or 2 are viable because of the harm they could cause to the interconnection customers in the earlier cycles who had previously withdrawn. Since the 2022 DPP cycle application deadline has not passed, incorporating the LRTP facilities into this cycle would allow more viable projects the opportunity to utilize the transmission capacity created by the LRTP upgrades. Xcel Energy also recommends incorporating the proposal to change the ERIS distribution factor from 20% to 10% in the 2022 DPP cycle along with the addition of the LRTP upgrades. The ERIS distribution factor change will have a positive effect on future congestion and curtailment and if incorporated into the 2022 DPP cycle along with the LRTP upgrades will have the least impact on the interconnection customers.
Thank you for the opportunity to provide comments, and American Transmission Company supports the following options:
Don’t include LRTP projects in the base case for the 2020 cycle but examine them on a case-by-case basis during GIA negotiations or afterward without repeating the studies. "OPTION 1" would be the case here.
Continue Phase 1 model delays until July 2022 for the 2021 cycle to fully integrate LRTP. It would be fair to have consistent topology assumption for all the DPP phases. "OPTION 1" would be the case here
National Grid Renewables supports the following ranking for each request:
2020 Cycles:
2021 Cycles:
We value certainty over faster results. There is huge value in having models and study results that include the LRTP projects; this will make GIA negotiations easier and quicker if all have the benefit of an official study incorporating the impacts of the LRTP projects.
Regards,
Devon Pehrson, Electrical Engineer II, National Grid Renewables
WPPI appreciates MISO raising this important issue in advance of Tranche 1 approval. We agree that, given the size of the Tranche 1 portfolio, the manner in which these projects are integrated into the interconnection studies merits careful thought.
We think this decision should be made based on considerations of fairness and avoiding disruption. We also saw some merit to Xcel’s suggestion, during the meeting, that in the event of a possible future decrease in distribution-factor impact threshold (which I understand Xcel is proposing), MISO consider pairing this change with recognition of LRTP projects, so that these two changes could partially offset.
We do see another set of relevant considerations, beyond impacts to the queue itself: potential congestion impacts to existing generators. If, as expected, the first tranche of LRTP projects is approved by MISO’s Board in July, these projects are likely to have much longer lead times than typical MTEP projects. This means that new generation allowed to interconnect on the basis of these future upgrades may contribute to congestion for a significant period before relief arrives in the form of major new 345 kV lines. While the newly interconnected generation might not be Deliverable during this period, that would not prevent it from being dispatched and potentially leading to down-dispatch of existing generation, including generation offered at $0. Given the extraordinary congestion already present in parts of MISO’s footprint, we believe MISO should consider special steps to limit the contribution to congestion from such resources, including delaying recognition of LRTP projects in generation interconnection studies.
In light of all these considerations, we are inclined to favor a relatively cautious approach to recognizing Tranche 1 facilities in the generator interconnection process. This leads us to a preference for Option 3 among the options MISO proposes, as this is the slowest timeline. However, we would appreciate the opportunity for further discussion, and perhaps consideration of additional alternatives before closing discussion of this issue.
ITC Holdings thanks MISO for the opportunity to comment on the LRTP integration options for Interconnection Requests discussed at the IPWG. For incorporating LRTP Tranche 1 into the 2020 DPP, ITC recommends Option 2. Not including LRTP in the base case and evaluating on a case-by-case basis during GIA negotiations, as indicated in Option 1, could lead to unnecessary work in processing GIAs and could be a burden on TO’s already strained resources. More certainty will be provided to interconnection customers and TOs, and less effort will be required for processing GIAs if the DPP 2020 is paused and LRTP is incorporated in the base case of phase 3 of the study.
For incorporating LRTP Tranche 1 into 2021 DPP, ITC recommends Option 1. Delaying study until the LRTP is incorporated into the Phase 1 base case will provide most reliable study results. Proceeding with Phase 1 study without incorporating the LRTP projects, as indicated in Option 2, would diminish the value of the Phase 1 study. Although the Phase 1 study could proceed in Option 2, its value in providing ICs with insight into future constraints and required mitigations for their projects would be questionable at best. Not including LRTP in DPP 2021 cycle, as indicated in Option 3, would ignore the potential benefits of LRTP in the 2021 cycle’s projects.
Steelhead Americas appreciates the opportunity to provide comments on integrating the LRTP into interconnection studies. As a generation developer with active queue positions, we prefer to incorporate the LRTP facilities as soon as practical, while minimizing overall study delays for current and future cycles. While some cycles will have LRTP facilities and others will not, we urge MISO to continue to follow its Tariff and BPM to ensure generators are given the flexibility and option to assess their impacts with or without specific LRTP projects, or the entire portfolio, in-service. Further, any interconnection study-identified Network Upgrade that is solved by inclusion of an LRTP facility should be removed for a generator (in conjunction with conditionality added to that LRTP facility), regardless of location or proximity to the LRTP facility or generator. Finally, as the LRTP construction and in-service schedule is, as yet, indefinite, there is a lot of risk for generators that accept conditionality on LRTP facilities. Therefore, MISO should provide firm expectations around LRTP in-service dates and allow additional flexibility and options to LRTP-conditional generators for a path to full interconnection if those expectations are not met.
The option we support is: Integrate LRTP only for upcoming 2022 cycle projects and beyond.
The reasons are as follows:
Generation interconnection requests that entered the MISO queue prior to DPP 2022 did so and made commercial decisions based on the system configurations without LRTP portfolio and therefore should proceed based on the expectations that were in place at the time of their application. It would not be a fair treatment if certain projects made the decision to drop out of the queue based on the system configurations without the LRTPs, while the projects that stayed receive the benefits of the additional LRTP capacity.
Clearway Energy Group strongly believes it would be more of a fair process for MISO to integrate the LRTP portfolio into the DPP 2022 cycle and beyond. This also is consistent with regular MISO MTEP project integration and DPP model building process. Many commercial and investments decisions have been made based on regular MTEP and DPP process and timelines, which established the expectation that newly approved MTEP projects will be applied to subsequent DPP cycles, rather than being applied to previous kicked-off DPP cycles.
Clearway Energy Group LLC
SunEnergy1 supports Option 1 for DPP 2020 cycle and Option 3 for DPP 2021. They cause the least delay and are consistent with the current process of regular MTEP model updates. It is reasonable to determine the impacts on a constraint-by-constraint (case-by-case) basis rather than delaying the entire cycle and subsequent cycles.
SunEnergy1 appreciates the opportunity to provide feedback.
Thanks,
Kun