In the March 16 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on the proposed GIP Timeline changes (IPWG003). Please provide feedback by April 2.
Transmission Owners Sector Feedback on Generator Interconnection Process Timeline Reduction Proposal and Tariff Language
April 2, 2021
In the March 16, 2021 meeting of the Interconnection Process Working Group (IPWG), stakeholders were invited to submit feedback on the MISO’s modified Generator Interconnection Process Timeline Reduction Proposal, and later also posted associated Tariff language for review. The following feedback is offered by the MISO Transmission Owners Sector for MISO’s consideration.
Comments on Proposal Modifications:
Since the last meeting of the IPWG, MISO has made several changes to the overall GIA negotiation and execution requirements. Most significantly, MISO is proposing to eliminate the requirement for Network Upgrade Facilities Studies (NUFS) to be completed prior to GIA negotiation, noting that the completion of the NUFS is not necessary for GIA negotiation, that FCA negotiation between the TO and the IC is part of the post-GIA execution and, in MISO’s opinion, is likely to result delays in GIA executions and overall GIP delays.
However, today the GIA does include details regarding Network Upgrades if the Upgrade impacts only one customer; they also impact the cost of the GI project and the payment milestones, which are calculated on the costs included in the NUFS. The NUFS also provides the key milestone dates necessary to populate the schedule information of the network upgrades. If the Network upgrades are tied to ERIS then this could affect the commercial operation date. Though these details are not included in the GIA for Shared Network Upgrades (or Common Use Upgrades), the MPFCA associated with these upgrades is typically executed at the same time as the GIA. The current process of starting GIA negotiations after Network Facility study completion gives a level of cost and schedule certainty that is not possible when the network upgrade costs and schedules are decoupled from the GIA process.
While the content of the GIA could be changed, as referenced by MISO in proposed Section 11.1, this approach does not seem to be in the best interest of Interconnection Customers because of the risk of loss of payments required at the execution of the GIA. This change may also the increased likelihood of GIA cancellations, which lead to queue delay due to re-studies, as well as churn in the GIA study process.
Moving the GIA execution ahead of the completion of the Network Facility study misses one of the key attributes of what the facility study does. The network upgrade proposals developed during DPP Phase 3 are simply planning level estimates of what “may be feasible.” At this point, very little information is known about routing, permitting, or outage coordination, all of which may be determined to be non-feasible during the Facility Study phase. Additionally, if ERIS requires NUs, COD will not be able to be determined until these studies are complete; moving to GIA under these conditions would increase rather than decrease uncertainty. Finally, ISD is determined in FS, which also determines capacity accreditation. “the Network FS (begins in Phase III) evaluates both ERIS & NRIS upgrades.
Regarding the timeline reduction proposals overall, there is also some concern regarding the impact of the shortening of the time allotted for the tasks overall on the accuracy of the outcome of the various studies and reports.
Alternate Approaches to GIA Negotiation Timeline Reduction for Consideration:
When an interconnection customer signs a GIA, they should have all of the information about the cost and schedule of everything that is necessary to get the level of service specified in the GIA. However, if the IC would like to move forward without complete information regarding the project cost, and schedule information, and the TO does not object to also executing the GIA absent the completion of these studies, the IC should be given that option. Additionally, projects with no NUs get to GIA negotiation at least 90 days faster than those with NUs, and these projects should be able to proceed to GIA as soon as possible.
This proposal does not address lengthy delays resulting from Affected System Study issues; perhaps MISO interconnection requests could be separated into queues of those likely to require Affected System Studies vs. those that do not.
Comments on Proposed Tariff Language
Section 11.1 states that draft Agreements will be tendered within 10 calendar days of relevant final reports being posted, and the Owners’ concerns with this proposal are stated above. The term "Interconnection Facilities Study" is not a defined Tariff term, and it is used interchangeably for facilities at the POI and facilities beyond the POI. Use of the term "interconnection Facilities Study" should relate only to facilities at the POI. The Tariff term, Facilities Study relates to Network Upgrades at the POI and remote from the POI, and it should be used accordingly. Using the terms interchangeably leads to much confusion.
Section 11.2 describes GIA Negotiation
The proposed language that begins this section is unclear, specifically because the prior section (Section 11.1) indicates that draft Agreements (GIA/FCA/MPFCA), will be tended “within 10 calendar days of final reports being posted.” With the tender of the draft Agreement being triggered by the posting of the relevant report, IC and TO comments could not be expected to be returned to MISO before the final relevant Report is issued. Thus the only relevant timing requirement is for the IC and the TO to return comments on the draft GIA/FCA/MPFCA, within 20 days of receipt of the draft, and the completion of the parts of the appendices for which Interconnection Customer is responsible.
Additionally, and more substantively, the timing of the initiation of the proposed 40 day negotiation period is not clear from the language proposed in this section. The proposed language refers to the beginning of negotiations, “ upon tender of the draft GIA, but also as commencing, “after issuance of the applicable final Interconnection Facilities Study reports applicable to the GIA and, as applicable, FCA(s) and/or MPFCA(s) that are subject to negotiation, and the final System Impact Study report.” While the intent of MISO’s proposed language is not clear, the Owners recommend that the negotiation timeline should not be triggered until the draft GIA has been tendered to the parties.
Section 11.3 addresses IC/TO Execution Windows, which are proposed to occur in parallel, within 45 calendar days of the receipt of the final Agreements. While the proposed timeframe would be acceptable, more time (60 days total) allowed for GIA execution would be preferable. However, the language proposed in Section 11.3 provides for only 30 days for the TO and IC to execute these agreements and allots 15 days to MISO to deliver the final agreements after completing negotiations. This is not consistent with the presentation to the IPWG, which states that the IC/TO GIA Execution Windows is 45 calendar days for both the IC and TO occurring in parallel.
The 30 days provided in the proposed tariff language for execution of GIAs is not sufficient, and as stated above, more time would be preferable. These are complicated agreements that may require management-level decisions, and overall it would be more efficient to allow more time for execution than to file unexecuted agreements at FERC which is costly and creates additional uncertainty pending FERC’s approval of GIA terms; the risk does not appear to outweigh the reward. Per the proposed language in this section, the risk associated with IC GIA execution also includes an IC payment of $250k in non-refundable site control security to the Transmission Provider after the GIA is signed.
To avoid the TO signing conditionally, it may be better to allow TOs an additional 15 days to sign after IC Execution. TOs may need to get internal approval to execute the final form of these agreements, whereas ICs typically have a total project budget that has been approved; this allows ICs some flexibility in managing their project that the TO does not have.
In addition to the comments above, the Owners will be submitting redlined changes to the tariff language posted following the March IPWG after further review.
Other Drivers for Queue Delays
Phase 2 delays are not addressed by this proposal but are typically driven by uncertainty in the IC’s plans or delays in receiving data necessary to perform short circuit studies.
Improving data quality/consistency review would also reduce Phase 2 delays. For example, inverter-based resources use default data that does not easily fit into study models and requires significant information exchange between ICs and TOs, which creates delays in the Phase 2 study.
The Transmission Owners appreciate the opportunity to provide feedback on MISO’s GIP Timeline Reduction proposal.
EDF Renewables, Inc. (“EDFR”) appreciates the opportunity to provide the following response to the request by the Midcontinent Independent System Operator, Inc. (“MISO”) for comments regarding its proposal to reduce the Generator Interconnection Process (“GIP”) timeline presented at the March Interconnection Process Working Group meeting. EDF Renewables, Inc. (“EDFR”) is supportive of MISO’s proposal to reduce the GIP timeline to approximately one-year.
NextEra Energy Resources, LLC (“NextEra”) appreciates the opportunity to comment on the Generator Interconnection Process timeline reduction proposal. NextEra continues to support MISO’s efforts to reduce the timeline from 505 days to roughly one year. NextEra believes that the proposed timeline, coupled with study reforms, will help to speed up the interconnection process and clear out the years of queue backlog.
Clean Grid Alliance Comments on GIP Timeline Reduction
March 30, 2021
Clean Grid Alliance appreciates the opportunity to provide comments on MISO’s March IPWG presentation regarding GIP Timeline reduction. We agree that it would be helpful on many levels to have a GIP processing timeline of approximately a year, but we also are very cognizant of the trade-offs needed to make this happen and have concerns that some of the reductions come at a big price for a small or gain, and may not be worth the trade-off.
Model review is an important step for both Interconnection Customers and Transmission Owners because errors in the model can be incredibly costly and impactful later in the process, particularly when discovered after the GIA (and impactful business decisions are made). We oppose any proposal to shorten this time from the currently allowed time.
In regard to running Facilities Study concurrently with the GIA negotiations- this may present a problem. Our understanding is that the interconnection facilities studies will be complete prior to GIA negotiations –please confirm if this is correct. A completed interconnection Facilities study is critical to have prior to negotiation. Among other points of negotiation, there may be ways to approach a substation differently, or configurations that require refinement and discussion to arrive at the “least cost” solution. Without seeing an initial proposal/plan, it’s impossible for the discussion/negotiations to occur. Similarly, the milestones are created based on the timeline for construction from the Facilities Study. The GIA milestones cannot be negotiated when timeline is not yet known. Ample time is needed after the Facilities Studies are complete, for the Interconnection Customer to provide feedback and negotiate various aspect of the GIA.
As we understand the proposal, the Network Upgrades facilities studies may not be complete at the time of GIA negotiation. Increases in cost between the Facilities Study and earlier estimates of Network Upgrades could be significant enough for an interconnection customer to need to drop, or to qualify for penalty-free withdrawal. There may be other circumstances as well, that should be carefully examined. We believe this requires a robust stakeholder discussion and consideration of all unintended consequences.
Sincerely,
Rhonda Peters, Ph.D.
Consultant for Clean Grid Alliance
March 30, 2021
Invenergy LLC ("Invenergy") appreciates the opportunity to comment on the most recent MISO GIP Timeline Reduction proposal presented at the March Interconnection Process Working Group. Running the Facilities Study concurrently with the GIA negotiation does not seem workable to Invenergy. The Facilities Study is when the timeline for construction is created, which the milestones are based upon. The GIA milestones cannot be negotiated when timeline is not yet known - MISO needs to finish the facilities study prior to GIA negotiations beginning or the timeline for construction and milestones must be known before GIA negotiations begin.
Thank you.
Nicole Luckey
Vice President, Regulatory Affairs
Invenergy LLC
WEC Energy Group is supportive of the efforts by MISO and stakeholders to identify possible reductions in the Generation Interconnection process timeline. However, we do not support changes that reduce the amount of information available to an Interconnection Customer prior to signing a GIA. The proposal to require execution of the GIA prior to completion of the Network Upgrade Facility Study report gives us pause because we prefer to have all relevant obligations identified prior to executing the GIA.