IPWG: Generation Replacement Process Enhancement (PAC-2023-4) (20240130)

Feedback Submission -

Muscatine Power and Water (MPW) is in support of this process enhancement proposal.

MPW agrees that the current generation replacement process is restrictive to generator owners seeking replacement to ensure reliability of both their native systems as well as the stability & reliability of the greater electric grid.   

MPW additionally agrees that the benefits prescribed here are likely to be realized from integrating flexibility into the replacement process as POIs which can be asserted as electrically similar but expressing considerably less interconnection costs represents values to utilities, developers, customers, as well as MISO’s vision to be the most reliable, value-creating RTO.  One specific comment MPW would offer is that language directed at electrically approximate POIs (i.e., busses connected via a single line at the same voltage level) as this seems better suited to the intent of reducing interconnection costs via tie line need mitigation than connecting at a different voltage level; however, given the considerations and description of ‘Generator Impact Test’ in Alliant’s proposal, it is possible that the proposal merits the voltage transformation language as well provided the replacement request meets that original intent.

Finally, this seems like an intuitive way to increase flexibility at the correct level – the interconnection request and between MISO and the original generator owner(s) or interconnection customer(s), as opposed to the utilization of a higher entity, such as a FERC waiver.

Best,

Greg Slonka

Muscatine Power and Water

Ameren – as holding company for:

• Ameren Illinois Company (d/b/a Ameren Illinois)
• Union Electric Company (d/b/a Ameren Missouri)
• Ameren Transmission Company of Illinois

Ameren appreciates the opportunity to comment on the Generation Replacement Process Enhancement presented at the IPWG by Alliant Energy.  We are in support of cost and time-saving efforts to add flexibility to the Generator Replacement Process. The Alliant proposal may give specific replacement projects enough flexibility to proceed in a timely manner.

American Municipal Power (AMP) appreciates the opportunity to provide feedback on the Generation Replacement Process Enhancement proposal presented by Alliant Energy.

As presented by Alliant Energy, AMP agrees that the current generation replacement process can create inefficient resource planning, duplicative system development, and unnecessary costs for customers. AMP supports the proposed solution detailed on slide 5 of Alliant Energy’s presentation, which provides for engineering analysis to determine what is an electrically equivalent Point of Interconnection.

AMP agrees that the proposed enhancement could provide benefits to reliability, customer costs, and overall interconnection process improvements. However, stakeholder comments should be fully reviewed and vetted to further refine the proposed process as needed before implementing any changes.

Generation Replacement is a very important process, and particularly so in the present circumstances of a rapidly evolving resource set and a severely strained interconnection process.  WPPI supports increased flexibility in the Replacement process, consistent with Alliant’s proposal, that would remedy the aspect of the current rules that may provide incentives for sub-optimal resource siting within a modernizing network.  We are open to narrowing Alliant’s proposal, as suggested by some stakeholders during the IPWG meeting, and encourage those with concerns to seek to identify modifications to Alliant's proposal that could assuage these concerns.

Mississippi Public Service Commission (MPSC) Response to Generation Replacement Process Enhancement (PAC-2023-4)

In the January 30, 2024, meeting of the Interconnection Process Working Group (IPWG) stakeholders were invited to review and submit feedback on Generation Replacement Process Enhancement (PAC-2023-4).

Please provide feedback by February 21, 2024.

Feedback

The MPSC supports proceeding with Alliant’s proposed enhancements so long as certain concerns can be considered and, if needed, addressed.

As concluded in FERC’s 2019 Order in Docket No. ER19-1065-000, an existing generator owner is entitled to use its existing interconnection rights when replacing its existing generation facility with a new facility, subject to certain limitations (e.g., the capacity of the new generator must not exceed the soon-to-be-retired generator). Midcontinent Indep. Sys. Operator, Inc., 167 FERC ¶ 61,146 (2019).

The Commission’s decision rested on the following:

-  Allowing replacement would avoid duplicative study costs and operational costs that otherwise would occur when the request to replace an existing                generating facility must proceed through the interconnection study queue process.
-  Allowing replacement requests would eliminate delaying replacement of older resources with more efficient and cost-effective resources.
-  Allowing replacement requests would preserve the rights of generation owners. It allows them to make infrastructure investment without losing their existing interconnection service and potentially incurring significant costs to obtain replacement interconnection service at the same location. Requiring owners of existing, interconnected generators to go through the full interconnection process, when the replacement generating facility uses the same type and level of service as the existing generating facility and will cause no material impact on the MISO transmission system, would be unreasonable.

The MPSC’s key concerns are as follows:

1. What constitutes the same Point of Interconnection. Alliant proposes to use “electrically equivalent POI” and to rely on engineering analysis, a shift factor test, and a neutral (No Harm) effect on other generators. (Slide 2).

MPSC Suggestion: Apply the No Harm test to resources in the interconnection queue, too. If the Replacement Point of Interconnection (POI) is different from the current POI, then the Replacement Request should not adversely affect the Interconnection Customer’s resource (e.g., not increase network upgrade costs or create operational restrictions).
MPSC Suggestion: The existing generator owner should explain why the new POI is advantageous (e.g., less expensive, improved reliability, avoids delays resulting from construction of redundant lines). (Slide 3).

2. Use of Owner-provided Certified Study Report: Alliant proposes (slide 5) that MISO would rely on owner-provided certified study reports to determine whether the replacement would burden (impact) the system.
MPSC Suggestion: This a great idea. It reduces the delay associated with MISO conducting the studies and issuing reports. As long as the report is issued by a vendor that MISO uses for similar studies or that MISO has otherwise approved, the MISO review process will be more efficient and timely.

3. Potential POI Locations: Alliant (slide 9) suggests that the alternative POI would be restricted to the same substation or lines connected to the substation with the retiring source.
MPSC Comment. Requiring the replacement to be connected to the same generator tie-line or a different location in the same substation yard, as long as it does not infringe on other generators or an impending interconnection request (e.g., with an executed GIA), strikes an appropriate balance between use of existing rights without precluding others from generation investment.
MPSC Comment. The MPSC questions Alliant’s third example (slide 10), which would permit the owner of existing generation that is interconnected to Substation A to retire that unit and interconnect a new replacement unit at substation B that is located 10 miles away. More information is needed to understand why that is a replacement instead of a new interconnection.

IPWG: Generation Replacement Process Enhancement

(PAC-2023-3) (20240130)

due February 21, 2024

In the January 30, 2024, meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on the Generation Replacement Process Enhancement proposal introduced into the MISO stakeholder process by Alliant Energy (Alliant).

Apex Clean Energy (Apex) appreciates the opportunity to submit the attached comments supporting the Alliant proposal with some slight modifications.

DAVID DAVIS

Senior Director

Transmission Regulation and Strategy

 Apex Clean Energy

120 Garrett Street

Suite 700

Charlottesville, VA  22902

Wolverine supports the concept of Alliant's proposal to introduce additional flexibility for the point of interconnection (POI) within MISO's generator replacement process. Therefore, Wolverine supports continued dialogue to identify reasonable electrically equivalent criteria that gives generators options without introducing new system impacts.

ITC Holdings feedback on IPWG Generation Process Enhancement (PAC-2023-4) 

ITC appreciates Alliant’s objective to provide flexibility to generators with current interconnections that allow they to cost-effectively use their existing interconnection service.  We understand that Alliant believes this proposal could help existing generators by reducing the need for new interconnection lead lines when they move to new locations.  From the presentation, we understand the overarching objective is to transform generator interconnection rights and that they are open to certain “guardrails.”  We also recognize that Alliant believes this might also create an opportunity for generators to develop partnerships.  Alliant also noted during the presentation that they do not see this proposal changing the “current state of play of the process today.”

ITC values the stated objective of MISO and stakeholders striving for effective and efficient processes.  The existing generator replacement process can be an efficient way to bring new generation online and we recognize that the rules in place are there to protect fairness and to provide equal opportunities to bring generation online.  We are concerned that the proposed BPM changes by Alliant could create a situation of unequal and potentially preferential treatment for existing generator owners by way of “queue jumping” to bring their projects online much quicker than a new generator going through the interconnection queue.  ITC has discussed these concerns with Alliant in one-on-one meetings and at the most recent IPWG.  We review our concerns below: 

Proposed Study Process:

Alliant is proposing two tests for generators to determine whether the new POI would be electrically equivalent:  the qualified change process and a shift factor test.

• ITC has concerns that these tests are not appropriate because the Qualified Change study is used for comparing performance between changing generation facility equipment using equivalent modeling and contingency analysis assumptions. Moving the POI by default creates a new scenario and is not an direct a comparison because the contingency sets and thus the flows on the transmission system are not the same. 
• Using DFAX cutoff thresholds to determine power flow impacts can also have cumulative effects as ITC had seen over time with historic ERIS projects contributing to increased congestion and in some cases driving the need for MTEP projects to maintain deliverability for existing projects. The DFAX thresholds used in DPP studies were recently lowered because of this “cumulative” effect (BPM-015 updates resulting from PAC 2022-3). Any amount of headroom left for potential overloads not requiring mitigation by one specific project due to not hitting the threshold can add up over time and could eventually require an MTEP fix or cause base case overloads in subsequent queue studies which would be paid for by someone other than the generator seeking replacement under this proposal.

Potential Scenarios Discussed:

Alliant described three potential scenarios, some of which ITC believes are problematic:

• There may be unique circumstances where allowing a change in connection to a different voltage class in the same substation may be an acceptable exception (for instance, the retiring generator is connected to a voltage that has known and established plans to be retired by the TO, for example ITCM’s 34.5 kV system), but in general this would not be considered “electrically equivalent”, as the different connection point would have a different set of contingencies and may produce different flows on the system.
• Similarly, moving from a connection point at an existing station to a new station along one of the lines out of the previous station would change the contingency flows. For instance, if the initial POI station had 3 outlets, and the new POI was one of those outlet lines but no additional lines are brought into the new station, there would then only be 2 outlets, and for example a contingency involving loss of the line section between the old and the new station would force all of the flow in one direction that was previously one of three outlets and potentially have negative reliability impacts.

Equity to Generators in the current queue:

There are a number of other considerations to this proposal, the potential impacts on generators in the current queue.

• Any allowed changes to a new POI for a replacement generator should have limits in proximity to the original retiring generator’s POI, as the further it moves away it functions more like a new interconnection request and not a “replacement” and as previously mentioned is just a way to jump ahead in the queue.
• While a shift factor or DFAX analysis could analyze changes to the power flows, it does not resolve the issue where the existing generator is “queue jumping” to a new connection point. To elaborate, there could be a situation where the higher voltage station only has one available position. If the retiring generator takes that position under a replacement project (which can be submitted at a time related to its retirement date and not bound by queue application windows), but another non-incumbent generator (currently in the queue) also was requesting a POI at that same higher voltage bus, it is likely under the Alliant proposal that the incumbent generator will be granted that POI. This leaves the non-incumbent generator harmed by additional station expansion costs. 
• As discussed above, there are circumstances where an incumbent generator replacement at a new POI could create increased upgrade costs for those currently in the queue.

Existing Remedies:

In closing, we note that there are existing mechanisms that could be utilized if the generator owner has a high confidence level their selected new POI will have minimal upgrades required, such as the provisional GIA (PGIA).  This would allow for the project to advance on their requested timeline but not “queue jump” in front of similarly situated generation projects. Appendix H of the pro-forma GIA (Tariff Attachment X Appendix 6) and BPM-015 Section 6.2.9 detail the ability to advance a provisional GIA while the DPP interconnection studies are still in progress. In addition, as MISO noted during the discussion, generators can work with MISO today to request a waiver for POI changes. 

ITC Recommendation:

ITC recommends that MISO and other stakeholders not adopt this proposal for the reasons discussed above:  the studies proposed are not adequate to identify system impacts when the replacement moves POI, the change in voltage for service is not an electrically equivalent, and the change will be potentially detrimental to generators in the queue.  Finally, the current BPM language provides sufficient remedies to meet the identified need of replacement generators to change point of interconnection.  While well intended, the Alliant proposal as presented provides too much flexibility for incumbent generators and could create a discriminatory situation with those in the queue. 

DTE is in support of Alliant’s proposal to provide existing Generator Owners with more flexibility in the point of interconnection (POI) they select for generator replacement projects.  We find the current tariff language, which requires the POI to be at the same substation and at the same voltage, to be very limiting as opposed to studying a proposed POI based on its electrical characteristics.  The changes that are being proposed will remove the current limitations and allow stakeholders to take full advantage of the benefits that the generator replacement process can offer.  Considering both concerns around resource adequacy and the length of the queue process, it is imperative that MISO and stakeholders remain open to policies that can accelerate the transition to clean energy in a cost-efficient manner. 

In its order accepting the current generator replacement process, the Commission partially justified its decision by acknowledging that existing generator facilities have already been studied and have incurred costs for network upgrades, therefore re-entry into the interconnection queue is not necessary.  The comprehensive tests included in this proposal are consistent with other screens by MISO to determine a projects impact to the system and other generators. 

We look forward to more discussion on the topic.

EDP Renewables (EDPR) appreciates the concerns raised by Alliant Energy and share in the urgency to expedite projects in the MISO queue. Despite sharing those concerns, Alliant’s proposal removes guardrails that prevent discriminatory treatment of similarly situated interconnection requests and fails to address potential reliability issues. 

Under this proposal, the definition of “electrically equivalent” is stretched to potentially including placing replacement generation at new substations, voltage levels, and/or circuits.  The proposal would allow generators to be deemed electrically equivalent as long as the facility doesn’t have more than a 5% for NRIS or 10% for ERIS shift factor on existing generation.  Those thresholds are used to establish cost responsibility for network upgrades not for understanding reliability impacts of new generation.  The proposal lacks reliability assessments that would be required to meet NERC standards and fails to account for broad impacts such a move could have on generation and reliability.  Assessments would need to be performed to determine impacts to Affected Systems, sub-transmission, and operations that are normally part of the DPP process. 

Additionally, moving the POI would significantly increase the required Network Upgrades required for the replacement generation.  Upgrades could include new interconnection substations, remote end relaying, and new fiber.  Many Transmission Owners are experiencing supply chain issues on equipment such as circuit breakers and control houses.  They are also limited in their ability to perform the required Facility Studies and engineering work to support new network upgrades.  Allowing a subset of projects to bypass the queue hurts generation that is in the queue competing for the same resources to come online. 

EDPR equally shares in the goal to accelerate projects through the MISO queue, but cannot support the Alliant proposal at this time. 

The OMS Transmission and Resources Work Groups (TWG and RWG) provide this feedback to MISO on Alliant’s Generation Replacement Process Enhancement (“proposal”). This feedback is from OMS work groups and does not represent a position of the OMS Board of Directors.

The TWG and RWG appreciate Alliant for developing and presenting this proposal and view it as a reasonable improvement to MISO’s existing generation replacement processes. Under the proposal, resource owners would be able to optimize the use of their existing Points of Interconnection (POI) when considering generation replacement options by removing the restriction that replacement projects must connect at the same voltage level and the same substation of the interconnection substation. The TWG and RWG agree that the current definition of “same electrical Point of Interconnection” in MISO’s tariff (i.e., requiring the same voltage) unnecessarily restricts resource owners from connecting at more advantageous POIs, which can lead to longer lead times and additional project costs during the replacement process.

If implemented, the proposal would provide more flexibility within current processes, increase resource planning efficiency, and reduce costs for customers by better utilizing existing interconnection rights. As currently designed, the proposal allows for a project to be determined as located at the same electrical POI if its integration in the POI requires upgrades equivalent to a distribution factor (DFAX) equal to, or less, than 5% for Network Resource Interconnection Services (NRIS) and equal to, or less, than 10% for Energy Resource Interconnection Services (ERIS). These guardrails allow for greater flexibility at the moment of interconnecting a new asset to the POI in question. MISO and stakeholders should explore what additional guardrails and study processes are needed to ensure other interconnection customers that are progressing through the queue are not harmed by this additional flexibility.

Xcel Energy appreciates that Alliant Energy is thinking about new approaches to enhance the MISO Generator Replacement process.  However, Xcel Energy does not support a MISO FERC filing that would seek to modify the current Tariff rules for Generator Replacement.