Informal Feedback (202310)

Otter Tail Power Company has been following MISO’s effort to continue to refine and improve the generation interconnection process.  We would like to thank MISO for this effort and the opportunity  to provide feedback on MISO queue improvements presented at the September 18 PAC meeting.  As a vertically integrated utility, we offer these comments both as a Transmission Owner and as an Interconnection Customer (IC).  We have also signed on to the MISO Transmission Owner comments. 

With respect to milestone payments, Otter Tail agrees that the key to improving the interconnection queue is to study viable projects and reduce speculative projects.  Otter Tail agrees with MISO the initial milestone payment of $4,000/MW is not accomplishing this and supports increasing this milestone requirement.  Initially, MISO proposed increasing the M2 Milestone payment to $12,000/MW and has since reduced their proposal to $8,000/MW.  Otter Tail felt the initial increase of M2 to $12,000/MW was a reasonable value when considering MISO’s goal and could support the modified proposal to increase of M2 to $8,000/MW.

In regard to site control, Otter Tail supports MISO’s current proposal with one exception.  Otter Tail does not support MISO’s proposal for 100% site control of the Interconnection Customers Interconnection Facilities prior to GIA execution or with an approved exception because it would hinder the flexibility of the Interconnection Customer and the Transmission Owner to perform the final design and siting of a greenfield substation.  Otter Tail could support 75% as an alternative.

Setting site control requirements at 75% percent of the Interconnection Customer Interconnection Facilities prior to GIA execution or with an approved exception will accomplish the goal of incenting viable projects to proceed through the queue process, but also provide the flexibility that a Transmission Owner needs, especially for greenfield POIs.  Below are reasons of why Otter Tail sees the need for flexibility, in particular for greenfield POIs:

• We believe it is important for the Transmission Owner, with input from the IC, to site the greenfield POI substation since it would be owned and permitted in the Transmission Owner’s name.
• We have had instances where ICs proposed locations of a greenfield POI substation that have not worked from an engineering perspective as Otter Tail would not have been able to get lines into and out of the proposed location.   
• We have also had ICs propose a substation location that would have triggered a long state-permitting process. 
• Otter Tail also has had Interconnection Customers propose substation locations where the land was not suitable for the construction of a substation and moving the substation was a better solution. 
• Finally, we have had instances where multiple generators in the same queue cycle have interconnected to the same greenfield POI substation, resulting in cost savings and time savings for the Interconnection Customers.  The resulting common POI, a solution providing benefits to the Interconnection Customer and the Transmission Owner, would not have been possible under the MISO POI proposal.

Finally, on developer caps at this time, we encourage MISO to monitor future cycles and re-evaluate the need for a developer cap in the future.