PAC: GIP Timeline Updates for BPM-015 (20230125)

HMKY supports the changes made to the Generation Interconnection BPM 15, that incorporates the FERC approved timeline that decreased the time to complete the study from 505 calendar days to 373 days. 

Transmission Owners Sector Feedback on Proposed GIP Timeline Updates for BPM-015

February 8, 2023

In the January 25, 2023, meeting of the Planning Advisory Committee (PAC), MISO presented proposed BPM-015 language to support Generator Interconnection Process (GIP) timeline update and invited Stakeholders to submit feedback.  The comments below are submitted by the Transmission Owners Sector (Owners or TOs).

1.  The Owners have general concerns with the lack of detail in the proposed BPM-015 Language. The Owners are concerned that the proposed language lacks sufficient detail regarding the timing of specific activities to provide clarity on the expectations of all parties, which is needed to properly plan for the resources needed to meet the compressed timelines of the revised GIP, further challenged by the size of the queues in upcoming DPP study cycles, which outpace anything experienced before. 

Examples where ambiguity is observed by the Owners are provided below but may not include all areas where clarity could be improved, and the Owners request that MISO review the proposed language further with this consideration in mind.

2.  The lack of detail in the proposed BPM language creates ambiguity regarding how slippage by one party impacts the overall timing expectations of other parties relying on the output that is delayed.  This is of particular concern to the Owners, given the number of deadlines applicable to deliverables that are required by the Transmission Owner, the Owners obligations to meet these deadlines, and MISO’s obligation under Order 845 to report delays and the reasons for them, as the Owners expressed in the process of drafting the associated language approved by FERC in Attachment X.

• To address this concern, the Owners suggest that MISO include language noting that the responsible party must use “Reasonable Efforts” to complete the referenced tasks within the timelines stated in the BPM.  This would be consistent with the flexibility of the overall DPP timeline noted in the proposed language of Section 5 of BPM-015 and in Section 7.3.2 of the GIP, in reference to the completion of Facilities Studies by Transmission Owners.

3.  Scheduling the Resources needed to complete these tasks

While GIP timelines can be reduced on paper, study cycles are likely to continue to be delayed.  This is a concern of the Owners, and likely Interconnection Customers as well, with regard to resource-scheduling.  When a study cycle is delayed, even though the overall timeline for the study stays the same, resource availability may have shifted for those who have planned their resources around the anticipated DPP schedule, making the overall DPP timeline more difficult to accomplish.  For example:

• MISO just announced a 30-day delay in starting the current queue. 
• For the DPP 2021 queue, it is very unlikely that the DPP Phase 1 can be completed in 65 (or even 90) days, given the large number of projects and MW in the study, which drives a large number of Limiting Element / Contingency Element pairs that correspond to a large number of necessary upgrades, for which solutions must be developed and  modeled by the Transmission Owner and tested by MISO, a process that takes several exchanges of information.   Following the determination of the final solution set, the TO must then come up with planning level estimates for each of the mitigations in the final solution set.  The same concept is true for other timeline reductions.  These concerns, along with proposed solutions for addressing them, are further described further below.

Examples:

Section 5 of the draft BPM language indicates that, “An Overview of the DPP is shown in Figure 5-1”

• The referenced flow diagram is not labeled as Figure 5-1 in the draft posted for review.
• The flow diagram shows the Path 1 and Path 2 options for GIA negations, and that Path 1 is the default, but it does not indicate when an IC would elect Path 2 if that’s their preference, which MISO should be noted.
• The flow diagram does not include the pre-study model review noted in Section 5.1.2.

Similarly, Section 5.1.2 states:

Except as otherwise provided in Section 5.7 of the GIP, at least ninety (90) Calendar Days prior to the scheduled kick-off of DPP Phase I published on the MISO public website as of the application deadline for entry into the next Definitive Planning Phase Cycle, the Interconnection Customer shall submit one of the following to the Transmission Provider:  

There is no list of what the IC shall submit; MISO should complete that section.

Section 5.2 – Results of Phase 1 SIS

Section 5.2 states, “the DPP is designed to provide the IC with a preliminary detailed analysis of their IR’s impact on the reliability of the Transmission System.”

The Owners suggest that MISO consider deleting or modifying this statement to better reflect the Results of Phase 1 SIS.  While the DPP Phase I SIS will provide the IC with the interconnection facilities that are needed

• the Phase I SIS does not include the full suite of studies needed to provide detail results on the impacts of the IR to the Transmission System, and
• the Phase I SIS results include the impacts of all generation in the queue, which is broader than the impacts of “their IR’s impact on the reliability of the Transmission System” 

Sections 5.2 and 5.2.1 – Study Models

The descriptions of the model building and review process in these two sections is unclear and should be updated to provide additional detail.

• Section 5.2 describes the overall scope of DPP Phase one, and states, “During this phase MISO will perform the initial Model Building and Review, which is scheduled for ten (10) Calendar Days.”
• Section 5.2.1 describes Model Building and System Impact Study, and begins with, “Prior to starting the preliminary SIS, MISO will distribute the study models to the IC and the TO.” and allows “ten (10) Business Days after receipt of the study models” to “recommend changes to the study model” using the referenced form.

The language above creates confusion in several areas:

• Section 5.2 refers to “the initial” model building and review, for which 10 days is scheduled, while Section 5.2.1 indicates that ICs and TOs will receive study models “Prior to starting the preliminary SIS”
  • If 5.2.1 intended to further describe the “initial model build” this is confusing because the initial models must be built in order to have been provided to the ICs and TOs for review.”  Thus, the word “initial” is confusing in Section 5.2.
  • The Figures included to illustrate this process do not include the model review phase “Prior to starting the preliminary SIS.
    • When can ICs and TOs expect to receive the models for review?
    • How do the 10-day periods referenced in these two sections relate to each other?  Are they the same 10 days?

Sections 5.3, 5.4 and 5.4.1 – DPP Phase I and Phase II

These sections reduce the time provided for model review and updating from 10 business days to 6 calendar days and indicate that MISO will move forward if no comments are received.  Given that the BPM language does not specify when the models will be provided to the ICs and TOs, and there is also no minimum number of business days included, the language as drafted places all of the timing burden on the TOs and the ICs, with no indication of when the models can be expected to be provided for review.   

• The Owners are concerned with how a delay in interim deadlines such as these will be reflected in meeting the timing requirements for the task overall.  For example, if MISO’s model review is delayed, would the delay roll into the time allotted in the overall study process, and potentially result in the overall slip in deliverables being attributed to the Owners if the study is not delivered by deadline. 
• These timing requirements should reflect more flexibility with regard to the timing of the IC and TO review, and qualify these deadlines as “best reasonable efforts” and should allow the IC and the TO to notify MISO if additional time is needed for review, in particular if MISO is notified that the IC or TO will have corrections, but that more time is needed to complete the review.