IPWG: Proposed Attachment X Updates (20220606)

PGR appreciates MISO’s intention to provide clarity in its Interconnection Procedures and associated Appendices and provides the following comments for MISO’s consideration.

1. The proposed definitions should be aligned across all of the various Tariff sections and should align (to the extent applicable) with the defined terms in Module A of the Tariff. PGR has identified that certain terms, e.g., “Calendar Day” and “Business Day” are not included in each agreement’s defined terms, but are utilized in each agreement. PGR recommends that a holistic review of the Defined Terms and applicable Definitions sections be conducted to ensure completeness, accuracy, and consistency, generally. Finally, PGR notes that the definition of “Reasonable Efforts” has been modified from the definition of the term in the Tariff generally. This revision was indicated as being for consistency purposes in the presentation, but the reason for deviating from the overall tariff definition was not addressed. PGR is concerned that variations in the definition associated with this term will cause ambiguity and confusion and will result in differing interpretations of “Reasonable Efforts” by MISO customers. PGR recommends that this revision not be implemented.
2. Relative to the new language regarding achievement of the Commercial Operation Date for replacement generation in Section 3.3.1 of Attachment X, PGR respectfully offers that such language should be modified to afford the replacement generation the same flexibility and option to request an extension of that date pursuant to Section 4.4. as would have been available to the initial generating facility.
3. Relative to the proposed revisions to Attachment X, Section 7.6.2.4 regarding the withdrawal and refund timeline due to increased Network Upgrade costs, MISO’s proposed five business days for withdrawal after the Final System Impact Study and Interconnection Facilities Study does not align with other parts of the process and does not give sufficient time for interconnection customers to make an informed decision to withdrawal.

Realistically, it takes a couple of business days at minimum for interconnection customers to arrange meetings with internal decision makers to work through study results. Therefore, a five-business day deadline does not provide adequate time for interconnection customers to conduct internal analysis, contact MISO if there are questions about the study results, and achieve resolution of those questions in time to make the decision to withdraw.

For the reasons above, PGR proposes that MISO adopt 15 business days – which would allow interconnection customers sufficient time to make a decision and would align with the timeframe for withdrawal after Decision Point I and Decision Point II.

4. Relative to the proposed revisions to Attachment X, Section 7.6.2.4 regarding the threshold for increased Network Upgrade costs, MISO’s proposed “and” criteria is unnecessarily restrictive. In particular, increased costs must meet both the % and $/MW criteria to be eligible for refund. Further, such criteria are evaluated only with respect to the last study result, not previous study results. Such criteria and the method of evaluation of the applicable inputs to the criteria are unnecessarily restrictive and do not account for the multiple phases of the process throughout which costs and upgrades identified could increase. To ensure that the process is equitable and reasonable, PGR would offer that the criteria should be an “or” statement and, further, that the inputs should be evaluated across all the previous phases, not merely the most recent phase.

5. Relative to Appendix A of the MPFCA, a revision was made to add “irrevocable” as a clarifier to security. Given the different types of security that could be provided, this clarifier could be problematic, depending on the type of security being provided. Additionally, since the current Tariff language already provides that security is required to be acceptable, MISO already has the opportunity to reject security that would not meet its requirements and purposes. PGR recommends that MISO not implement this revision to avoid complications that could arise based on security type.

Thank you again for the opportunity to provide input to your proposed revisions.

Thank you for the opportunity to comment and for your efforts made to clean up and better clarify in Attachment X  of the MISO Tariff. EDF Renewables has the following brief comments:

• EDFR supports the Tariff additions and edits offered regarding the COD for replacement generators and the GIP 11.3 and 11.4 revisions.
• For the penalty free withdrawal provisions, please note that while we support the Tariff changes proposed in the presentation, we would like to extend these provisions to also pertain to affected systems (AFS) costs, specifically as these AFS costs have become more volatile for some study cycles and similar changes to those provisions (in addition to those proposed for MISO costs) would protect generators from late stage cost increases after signing interconnection agreements.

ITC Holdings thanks MISO for the opportunity to provide comments and proposed revisions in the IPWG: Proposed Attachment X Updates (20220606) discussed at the IPWG.

ITC appreciates the work MISO has done on its revisions to Attachment X of the MISO FERC Electric Tariff for Generator Interconnection Procedures.  While ITC appreciates the opportunity for prior notice that must be provided to other parties prior to an assignment of ownership of an Interconnection Customer, ITC would like to see the addition of the follow section to the Tariff to cover those situations where there is a transfer of ownership, but it is not technically an assignment of the GIA to another party.

19.2     Changes in Interconnection Customer Ownership.  Where the Interconnection Customer is a business entity and a transfer by sale or otherwise would result in a change in the majority of its equity ownership, the Interconnection Customer must provide prior notice to the other Parties and allow an opportunity for the other Parties to evaluate and accept or reject the creditworthiness of such proposed new majority ownership.

ITC would be willing to discuss this proposed addition with MISO.

Alliant Energy has one comment regarding the proposed Attachment X updates, specifically section 3.3.1.  Alliant Energy understands the rationale behind MISO's proposed edit to this section to prevent "squatting" of interconnection rights.  However, to provide more clarity Alliant Energy supports the alternative redline edits below.  These edits will help make clear that the treatment of the new replacement facility will be equal to that of the original replacement facility including the ability for the replacement facility to extend the COD under standard GIA provisions.

“For Existing Generating Facilities that have not yet reach Commercial Operation, the specified Commercial Operation Date in the GIA of a Replacement Generation Facility shall be no later than the specified Commercial Operation Date in the GIA of the Existing Generation Facility.”

Arevon comments on Proposed Attachment X Upgrades

June 22, 2022 

Comments on proposed update to Att X 3.3.1:

A Replacement Request allows an Interconnection Customer to replace generating units at an Existing Generating Facility with more generating units or storage devices. As per Figure 6-4 of the BPM-015, the entire duration from IC submitting the Replacement Request to MISO tendering or amending the GIA could take close to a year. It would be impossible for a Replacement facility to achieve COD the same time as the existing generating facility. Also, if Replacement facility gets added to the existing interconnection request and deemed a replacement generating facility, how can there be any harm to MISO’s queue? The replacement facility is limited to the Interconnection service, type of service of the existing generation. Instead, can MISO start the clock with a different timeline for Replacement Requests?

 Comments on proposed update to Att X 7.6.2.4:

As we understand, the definitions of Final SIS and Revised SIS refer to the difference between Phase III and phase II. The existing language provided clarity on the phases, what is the purposes of removing the phase details.

 Comments on proposed update to Att X 11.4:

Can MISO clarify if the proposed language with respect to unexecuted filing requires Interconnection Customer to comply with every term in tendered GIA/FCA/MPFCA even if the agreement(s) is filed unexecuted.

We appreciate MISO's efforts to consider stakeholder input on the topic.