In the March 1 meeting of the Planning Advisory Committee (PAC), stakeholders were invited to submit feedback on proposed Replacement Interconnection Process Improvements tariff language.
Comments are due by March 23.
National Grid Renewables supports the added option of a longer-term study scenario within the Reliability Assessment Study, and understands and supports the need for a 30-day lead time on attachment Y submission before suspending service
The Environmental Sector appreciates the opportunity to provide comments to the Planning Advisory Committee on proposed Tariff edits to MISO’s proposed Replacement Process Improvement Tariff changes. While we see potential benefits from the proposed changes, we believe that without additional changes a critically important opportunity will be lost to update outdated and harmful policies related to generator retirements.
MISO has proposed to allow additional studies in the Generator Replacement process such that projects seeking Generator Replacement, if they choose not to go forward with the replacement, can expedite their retirement under Attachment Y. Although we are not opposed to offering flexibility, there should be increased transparency with this increased flexibility. The proposed changes should be improved by requiring that public information be posted in regard to the additional study being undertaken that would expedite retirement, should the generator choose not to move forward with the replacement. Additionally, the replacement studies should be made available to any entities with CEII and NDA clearance, just as all generator interconnection studies are. We also encourage MISO to consider how it can add additional transparency to the existing Attachment Y process.
The TDU Sector supports proposed changes to the generation replacement process and appreciates MISO’s continued efforts to refine the process. A further improvement to the replacement process supported by the Sector is addressing the restriction that replacement requests not be made less than one year from the suspension date of a resource. The TDU Sector recognizes MISO requires time to complete necessary studies prior to the COD of a replacement resource. However, in cases where the COD of a replacement resource is greater than one year from the suspension date of the existing resource, the Sector does not see the need for the current one year restriction. The Sector suggests a slight change to the current one year restriction to note this is only appliable if the requested COD of a replacement resource is less than one year from the date of the replacement request.