MISO is requesting feedback on Generator Replacement Request Proposed Tariff Changes.
Please provided feedback on the following Tariff redlines:
Please provide feedback by May 25, 2023.
Clean Grid Alliance Comments the IPWG on Proposed Changes to Generator Replacement
May 25th, 2023
Clean Grid Alliance appreciates the opportunity to comment on MISO’s presentations regarding changes to the Generator Replacement Process:
Clean Grid Alliance has questions and concerns in regard to the proposed requirement that once a generator replacement is approved, if it is not for the full amount, no other requests will be allowed, and the remaining megawatts will be forfeited (page 3). If a second request is submitted
it is not clear why, if there is still a year or more in advance of the retirement date, that additional MWs cannot be requested for Generator Replacement --please provide the reasoning behind this provision. Additionally, MISO responded during the IPWG meeting that if additional replacement requests for remaining MWs were submitted prior to execution of a replacement agreement, those would be accepted/studied. We believe this nuance is significant and should be captured in policy language. We also believe efficiencies can be realized if MISO were to allow at least 6 months after execution of a Generator Replacement agreement for any remaining MWs to be submitted for Generator Replacement.
Finally, we request that MISO shorten the requirement from 1 year in advance to 6 months prior to retirement to submit a Generator Replacement application, and that no time requirement be imposed in the case of a SSR designation. These two adjustments to the MISO Generator Replacement process will facilitate the efficiencies needed to swiftly replace generator retirements that are currently outpacing replacements. It will also result in savings to load in avoided SSR payments.
Vistra Corp. (“Vistra”) appreciates the opportunity to submit feedback on MISO’s proposed tariff changes to the Generator Replacement Request language in Attachment X that was shared by MISO during the May 2nd IPWG meeting. Vistra’s comments specifically address the new language included as part of Section 3.7.5, “GIA for Generating Facility Replacement.” MISO’s proposed language states, “If the MW of a Generating Facility Replacement request is less than the MW of the Existing Generating Facility that is being replaced, the Interconnection Customer cannot make any additional Generating Facility Replacement requests after the first GIA for the Generating Facility Replacement is signed.”
Vistra believes this language adds an unnecessary restriction that will chill the development of much needed- and in many cases, state mandated- renewable generation development in the MISO footprint. MISO’s IPWG presentation fails to explain how this restriction, that appears to eliminate the opportunity to submit more than one replacement request after the first GIA is signed, would “improve” the Generating Facility Replacement process. In fact, Vistra believes the proposed restriction will have the opposite effect, and lead to situations where in order to avoid losing MWs, certain generators may decide to submit a single, highly speculative, generation replacement request to ensure that they preserve their full interconnection rights prior to having complete certainty regarding the full level of replacement capacity that can be developed at the existing point of interconnection. The result will be greater uncertainty, as MISO will have less visibility into the portion of the replacement capacity that can reasonably be expected to reach commercial operation. By permitting interconnection customers to submit more than one replacement request, MISO will get a more accurate picture of what the future generation mix will look like.
It is important to recognize that the renewable and energy storage projects that are likely to account for a significant portion of replacement facilities are typically developed in phases based on the availability of state incentives, offtake agreements, and financing. Thus, while the owner of an existing generation resource may have plans to use all of its existing interconnection rights to support the development of replacement capacity, the owner may hold off on submitting replacement requests for discrete phases of the replacement facility until they are confident that they will be able to secure the funding or commitment necessary to support development. Ultimately, providing interconnection customers with the flexibility to submit replacement requests in a phased approach benefits both MISO and other interconnection customers by providing greater certainty that the capacity that is the subject matter of a replacement request will make it to commercial operation.
Additionally, the existing Generating Facility Replacement process already is subject to requirements that encourage developers to diligently pursue the redevelopment of their sites. For instance, given that the window for bringing a replacement facility online is limited, interconnection customers have an incentive to submit a replacement request as soon as they are comfortable with the viability of their proposed replacement capacity. As a result, the existing Generating Facility Replacement rules already create a disincentive for interconnection customers to sit on their interconnection rights, and instead, incentivize them to evaluate as expeditiously as possible, the replacement capacity that can be supported at the site. MISO’s proposal to impose further limitations on the rights of customers to submit replacement requests is inconsistent with Commission policy favoring the efficient use of existing interconnection rights and infrastructure to support the orderly replacement of retiring generation resources.
Consumers Energy recognizes that the new process being proposed still allows for an Attachment Y filing to be made prior to submitting a generator replacement request. We appreciate the added flexibility but want to ensure the original option remains as it will be prudent for certain competitive solicitation situations.
Consumers Energy has additional questions regarding the 3-year window clarification. In Section 3.1.1 of Attachment X, the expected COD must be within 3 years of cessation, but later the process describes a three-year grace period to achieve commercial operation. We want to clarify that the 3-year grace period after the initial expected COD still exists. Additionally, is there any flexibility around the grace period for events outside the interconnection control (e.g., supply chain issues, legal challenges, etc.)?
Thanks,
Nick Tenney
Consumers Energy
Invenergy thanks MISO for the opportunity to provide feedback on the proposed tariff changes to Generator Replacement Requests. Invenergy is concerned with the provision in the proposed amendments which would limit a retiring facility to only one replacement GIA.
Slide 5: “Partially replaced unit, no more replacement request is allowed after the first replacement request GIA signed.”
Invenergy understands the intent to increase visibility into how interconnection service is being used, and agrees with the reasonableness of some threshold, but believes that this limit is not the right approach and may lead to adverse consequences. Retiring facilities tend to have substantial interconnection rights from large facilities and replacement facilities tend to have fewer megawatts per GIA.
Left as is, this proposal would result in adverse impacts such as:
(1) lower utilization of existing interconnection headroom
(2) less flexibility for owners of retiring generation to utilize existing interconnection rights
(3) more filed queue positions, as projects that otherwise would have gone through generation replacement will need to go through the GIP.
Further, as MISO considers limiting the use of “hybrid” participation in the Market Subcommittee, the proposal may inadvertently decrease technological diversity of replacement facilities.
Invenergy believes a threshold is reasonable, but that any proposed threshold merits further discussion.
For the next IPWG, clarification on the following points would stimulate productive conversation:
The circumstances under which additional GIAs would be allowed under the existing proposal (as staff had stated that this may be the case during the IPWG),
The operational rationale behind the one GIA limit,
Whether increasing that limit to 3 or 5 GIAs would still fulfill that purpose, and
Whether another threshold, such as a time-based threshold, would fulfill the purpose of the limit.
Invenergy thanks staff for their consideration and looks forward to future discussion.
Alliant Energy appreciates MISO’s continued efforts to refine and improve the generation replacement process. Provided below are suggested edits to MISO’s proposal to provide further clarification.
In addition to the changes and clarifications which MISO has proposed, Alliant Energy believes further clarification and flexibility should be provided regarding how the term same electrically equivalent Point of Interconnection is interpreted. A replacement request needs to use the same electrically equivalent Point of Interconnection as the resource which is retiring. Alliant Energy believes MISO should allow for a demonstration to be made to support a replacement POI not at the retiring resource interconnecting substation but at an electrically equivalent location which does not have impacts to projects in the interconnection queue. This would be a valuable enhancement to the replacement process.
Alliant Energy edits to MISO Proposal: