IPWG: Initial Commercial Operations Date in GIAs (PAC-2023-3) (20240130)

BPM-015

1. How does this align with section 3.1.1 of Attachment X of the GIP? GIP states that the ISD cannot exceed 7 years from the Interconnection Request date. Is MISO proposing to reduce this to 5 years?

Attachment X:

1. Provision for TO requested extension of ISD of 2 years. - IC should be allowed to make an equivalent request as they would be potentially facing the same constraints.

2. Provision for minimum of 180 Calendar Days from ISD to COD - Does this provision only come into play if the ISD goes beyond the maximum allowed COD? As the 180 day duration is a minimum, would IC be forced to wait 180 days to go commercial even if the project is ready ahead of the 180 days? Will there be a maximum enforced duration from ISD to COD? More clarity is needed. A 270 day extension of the maximum COD should be allowed/instituted only when the ISD falls within 6 months of the maximum allowed COD. The 270 day extension should allow sufficient time for construction/commissioning and synchronization efforts especially in colder areas where ISD may fall just before winter, limiting acceptable working and testing/commissioning conditions.

Short-term Solution

Alliant Energy believes MISO should provide a blanket waiver on 2018 and 2019 cycle projects which provides a 2-year extension on the maximum COD.  All projects in these study cycles have been subject to significant delays in the study process.  In addition, supply chain issues continue to impact both transmission owners and generation developers.  A blanket waiver is the most efficient way for MISO to address this issue which impacts a number of queue projects.  The alternative to MISO providing a blanket waiver is individual waivers being filed to FERC.  Given the number of projects in these cycles, the number of individual waivers could be voluminous and create a large (and avoidable) workload for MISO staff.

Long-term solution

MISO has proposed a transmission owner may request an extension of in-service date of 2 years beyond the 3-year maximum during GIA negotiation.  Alliant Energy believes an Interconnection Customer also needs the ability to request a 2-year extension of in-service date if the MISO queue process has taken longer than the timeline defined in BPM 15.  Delays in the study process are outside the control of interconnection customers.  To balance the impact of unexpected and uncontrollable study delays, Interconnection Customer should have the ability to adjust their project timing accordingly.

EDP Renewables (EDPR) continues to advocate for flexibility to COD for projects that have experience delays outside of their control.  EDPR supports the five-year extension beyond the COD date in the original interconnection request.  EDPR has experience supply chain issues beginning with the DPP-2017 cycle.  EDPR believes that MISO should apply the five-year COD extension to the DPP-2017 and forward.  This will establish equitable rules that can be applied to all projects.  This change will address ongoing supply chain issues that many projects face and decrease the time and risk of filing a FERC Waivers individually. 

EDF Renewables appreciates MISO consideration of this very important issue which has become widespread among projects in multiple queue cycles.

For projects that have or are soon to be receiving and executing GIAs, EDFR urges MISO to consider an additional 2 year extension to the 3 years included in the current tariff language in Section 2.3.1 of the GIA, for a total of 5 years from the COD indicated in the GIA. A blanket waiver for all projects in these queue cycles will do much to address the various issues that have arise for projects that already have or will soon have executed/filed GIAs.  Doing so as soon as possible will do much to help address the uncertainty that projects in these cycles currently face about the lifespan of their GIAs. 

For projects that are still in the study process, granting an additional 2 years on top of the provisions of the existing 3 years granted in 4.4.4 of the Generator Interconnection Procedures (GIP) in Attachment X at time of GIA negotiation would be appropriate. This would allow for a refreshed look at the reasonableness of the original COD that was proposed in the initial application and provide a more meaningful window of adjustment after the completion of the studies.

Respectfully submitted,

Anton Ptak

EDF Renewables

The MISO Transmission Owners (Owners) submit the following feedback in response to MISO’s Commercial Operations Date (COD) in GIAs presented at the IPWG meeting January 30, 2024.

The Owners appreciate MISO’s review of the commercial operations progress for the DPP queue cycles.  The blanket waivers targeting the DPP 2018 and DPP 2019 cycles seem like a reasonable near-term solution for those projects while a longer-term solution is developed, and the Owners support this proposal.

For the longer-term solution involving Attachment X revisions, the Owners agree the current limitation of 3 years between the dates listed on the initial interconnection application for In-Service Date and Commercial Operation Date and what is allowed to be listed in the GIA is overly restrictive, based on the number of factors that contribute to construction schedules and can cause delays. 

Allowing for an additional 2 years to a total of 5 years between the In-Service dates listed on the application and the dates that can be listed in the GIA is a step in the right direction, but perhaps even better, would be to reference the timeline provided by the Transmission Owner as part of the Facilities Study for the project, and allow for negotiated dates in the GIA to align with the amount of time the TO reasonably expects it can complete the Interconnection Facilities based on when the project is moving to GIA rather than the date on the application.

In regard to the provision for a minimum of 180 days between the In-Service Date (ISD) and the COD, the Owners are unclear on the intent of this provision, and request MISO to further elaborate.  If the changes to allowable negotiated dates in the GIA’s make the listed dates for both ISD and COD more realistic and achievable, this seems unnecessary to preclude the option for an earlier date.

IPWG: Initial Commercial Operations Date in GIAs

February 20, 2024

In the January 30, 2024, meeting of the Interconnection Process Working Group (IPWG) MISO presented two proposals for stakeholder review relating to the Initial Commercial Operations Date in GIAs

• a blanket waiver for all projects that have or will have executed GIAs in the DPP-2018 and DPP-2019 cycles
• changes to Commercial Operations Date and In-Service Date provisions in the Tariff and BPM-015 that include extending the limitation of 3 years between the dates listed on the initial interconnection application for In-Service Date and Commercial Operation Date to 5 years.

The Entergy Operating Companies (Entergy) submit the following feedback in response to these proposals.

• Entergy supports MISO’s consideration of a blanket waiver for all projects that have or will have executed GIAs in the DPP-2018 and DPP-2019 cycles to address the delays experienced in these cycles for the reasons noted by MISO and Stakeholders
• Entergy supports changes to Commercial Operations Date and In-Service Date provisions in the Tariff and BPM-015 that include extending the limitation of 3 years between the dates listed on the initial interconnection application for In-Service Date and Commercial Operation Date. With regard to the timing of the In-Service Date and Commercial Operation Date, Entergy would prefer for these dates to reflect the timeline provided by the Transmission Owner in the Facilities Study, and tied to the timing of GIA negotiation, rather than the Application. 

While Entergy supports these proposals to better reflect more realistic timing of projects with executed GIAs that are moving forward, we have concerns relating to the lack of formality around the process for withdrawing GIAs that have been executed but are not moving forward.  Until these GIAs are cancelled, the associated projects must continue to be modeled in transmission planning and Interconnection Study models, which results in incorrect planning assumptions and may also lead to projects that are not being built accounting for capacity that is then unavailable to later queued projects.  To address this concern,  Entergy requests that MISO also include formalization of the process for cancellation of GIAs that have withdrawn since GIA execution or have not moved forward in this effort to improve the GIP.