PAC: Shared Interconnection Facilities Tariff (20220301)

National Grid Renewables appreciates the commitment to expediency in this process and agrees that it is appropriate to remove the requirement of TO sign-off.

The Environmental Sector appreciates the opportunity to provide comments to the Planning Advisory Committee on proposed Tariff edits to MISO’s Shared Interconnection Facilities policies. We strongly support MISO’s proposed changes and appreciate the effort and time put into this change. 

In the past year, there has been an increase in the number of renewable energy producers who have sought to share interconnection facilities between projects/queue positions for financial efficiency and benefit to the MISO system. We applaud and appreciate MISO’s effort to streamline the process making it less time consuming for interconnection customers, transmission owners, and MISO staff, while still ensuring that MISO’s needs are met both in the near term and in anticipation of any future changes in ownership.

WPPI would ask MISO to make a practice of posting draft tariff changes in MS Word format rather than pdf when requesting stakeholder review.  In addition we would ask MISO, when posting abridged documents, to be sure to include pages preceding changes as necessary to understand the context of the proposed changes.  These steps would greatly facilitate meaningful stakeholder review.

 Attachment X proper

• p. 2/9 of the posted document – Proposed added 4^th paragraph is not properly formatted and is not properly written as a condition consistent with the preceding listed paragraphs.  Consider changing, e.g., to “If sharing Interconnection Customer Interconnection Facilities with the Existing Generating Facility, the Interconnection Customer has entered into a consent agreement that meets the requirements of Section 3.3.1.4.”
• p. 5/9 of the posted document – Consider adding apostrophe to change “Transmission Providers” to “Transmission Provider’s”
• p. 5/9 of the posted document – revised provision within 3.3.1.5 now says that Interconnection requests must satisfy the terms of 3.3.1.5.  Self-referential tariff provisions are problematic.  Please review and consider adjustment.
• p. 7/9 of the posted document – Consider adding comma between dependent (if) and main (then) clause to yield “if the modified Point of Interconnection includes shared Interconnection Customer Interconnection Facilities, the Interconnection Customer shall submit a consent agreement that meets requirements of Section 3.3.1.4 by the beginning of DPP Phase I”
• p. 9/9 of the posted document – Consider changing the semicolon between dependent (if) and main (then) clause to a comma to yield “If the Interconnection Customer is requesting to share Interconnection Customer Interconnection Facilities as part of the proposed change, the Interconnection Customer shall submit a consent agreement that meets the requirements of Section 3.3.1.4 along with the identification of changes to the planned interconnection.