In the October 11, 2023, meeting of the Planning Advisory Committee (PAC), MISO requested feedback on proposed Inverter-Based Resource Performance Requirements. Proposed changes are to the draft Generator Interconnection Agreement language to adopt specific IEEE 2800 2022 performance requirements targeting system reliability support.
Stakeholders are invited to submit feedback by October 31.
Invenergy appreciates the opportunity to provide comment on the Inverter-Based Resource Performance Requirements presented at the October 11th PAC. Invenergy shares MISO’s dedication to industry best practices and understands the need to implement updated performance requirements.
However, a clause in the DPP22 implementation policy may completely undermine the flexibility MISO staff is hoping to provide. MISO’s proposal includes a phased implementation as a measure of flexibility for documented conformance issues. This flexible implementation allows for DPP22 projects to request good-faith exceptions to specific subclauses based on “documented OEM uncertainties or known inabilities to meet certain performance specifications.” As Invenergy has noted in prior comments, flexibility will be critical to the successful implementation of the IEEE 2800 standard, especially as IBR suppliers and industry work expeditiously to comply.
MISO’s proposed language to not grant exception requests for GIAs executed on or after January 1, 2025, (as written on slide 23) may unintentionally eliminate any proposed flexibility. While the most recent update estimates a GIA execution date for October 19th, 2024, any changethe study timeline risks eliminating all projects from eligibility for flexibility. Indeed, if recent history is any indication, it is almost guaranteed that no projects will qualify for this flexibility. Just in 2023, the DPP22 queue timelines have already been delayed eight months – the first DPP schedule published in 2023 estimated a DPP22 GIA execution date in February 2024. With the size and complexity of the DPP22 queue, it is unrealistic to assume that stakeholders will not see further delays, even in the next update.
Instead, Invenergy would ask that MISO provide the option for flexibility for all DPP22 positions, regardless of date of GIA execution. Invenergy would strongly advise MISO against coupling the timeline of implementation to a highly uncertain queue timeline, especially in the midst of queue reforms and FERC compliance filings. Successful implementation of similar standards in other markets has required prospective rather than retrospective requirements.
Invenergy thanks MISO staff for their time and consideration.
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Transmission Owners feedback on proposed Inverter-Based Resource Performance Requirements
October 31, 2023
In response to the feedback MISO requested at the October 11, 2023 meeting of the Planning Advisory Committee (PAC) on proposed Inverter-Based Resource Performance Requirements, the Transmission Owners support the proposed changes to the Generator Interconnection Agreement language to adopt specific IEEE 2800 2022 performance requirements targeting system reliability support, and we appreciate MISO adopting these requirements.
Clean Grid Alliance Comments on IBR Performance Requirements: Draft GIA
Oct 31, 2023
Clean Grid Alliance encourages MISO to address the need for flexibility for DPP 2022 cycle projects by allowing exemptions requests for this entire study group from meeting the new requirements. Setting a cutoff date such that only DPP 2022 projects that execute GIAs before 2025 would be eligible to request exemptions will not sufficiently address the need for flexibility, as the interaction of such a firm cutoff date with an uncertain queue study timeline creates unacceptable regulatory risk for DPP 2022 projects. We strongly encourage MISO to adopt language to allow for exemption requests by all projects in the 2022 DPP cycle and earlier, regardless of the date on which they execute a GIA. Finally, we want to also affirm our support of MISO’s accepting exemptions for legacy units that are unable to comply, as well as DPP 2022 and earlier projects which may have already ordered or procured equipment and are unable to adopt, among other reasons.