Informal Feedback (202303)

Clean Grid Alliance Comments on the Joint Targeted Interconnection Queue Process (JTIQ) Update
March 31, 2023

Clean Grid Alliance (CGA) would like to take this opportunity to provide unsolicited comments related to the latest of update of the JTIQ process.  

On March 27^th MISO and Southwest Power Pool (SPP) provided an update on progress toward the new proposed JTIQ process in regard to Southwest Power Pool (SPP) Affected Systems Studies (AFS). The presentation from this meeting can be found at:  

https://cdn.misoenergy.org/20230337%20MISO%20SPP%20JTIQ%20Update628357.pdf 

We generally support the direction of these reforms, but generators need more details on the proposal and the opportunity to fully weigh in, to ensure that the JTIQ is a fair and sustainable process. 

On slide 26 of the presentation, MISO notes a targeted date of June 2023 for stakeholder approval of this proposal to allow MISO and SPP to submit it to the Federal Energy Regulatory Commission (FERC) for approval of the required tariff revisions. With roughly three months left until that filing, a vast majority of information that is critical to this proposal, is not yet available for stakeholders to review. Some examples of the information not yet available to stakeholders includes, draft Tariff language and associated rate schedules, a description of the allocation of Department of Energy funds (if received), and updates to the JTIQ whitepaper describing the specific implementation of the new process. 

Generator Interconnection Customers (GICs) understand the urgent need to implement the right transmission solution to relieve the affected system issues between MISO and SPP and would like the opportunity to collaborate with MISO on several aspects of this proposal that already do not align well with the generation development process, and to also have input on key elements of the proposal that are currently only available to MISO transmission owners (TOs) such as the DOE application. Uncertainty on the cost and schedule for these projects is a significant hurdle for the generator subscriptions needed to significantly fund the JTIQ projects.

We strongly encourage MISO to avoid moving forward with a plan that omits input from the stakeholders most impacted by it, the generator interconnection customers who are proposed to pay for 90% (or higher) of the costs for new MISO-SPP backbone seams transmission. Generator interconnection customers are largely in the dark, as of today, on critical elements of the proposal, as evidenced by the questions asked during the March 27^th meeting, and the lack of answers provided. To be inclusive of all MISO stakeholders, we encourage MISO to promptly publish draft Tariff edits (and request/respond to at least two rounds of stakeholder comments), and provide updates to the Whitepaper, along with the preliminary DOE application and the upcoming detailed DOE application (when available, and with at least one round of stakeholder feedback/responses). Collaboration with all stakeholders, particularly those who are expected to take on the vast majority of risk and costs under the JTIQ proposal, will allow for a robust final product. MISO did not open up a comment request to capture the feedback or the remaining unanswered questions from the March 27^th meeting, but we look forward to a future opportunity to submit detailed comments and questions on the JTIQ proposal that have been collected to date. 

March 31, 2023
Comments of American Clean Power Association (ACP) and Clean Grid Alliance (CGA) 

ACP and CGA thank MISO for its reply letter dated February 17^th, 2023, and for the additional presentation on the implications of a change to MISO’s Distribution Factor (DFAX) at the Planning Advisory Committee on March 8^th. ACP and CGA continue to believe that 10% is an arbitrary number and MISO has not provided study work to prove this specific number will actually solve the deliverability or reliability issues MISO thinks it will. It is the wrong solution to an issue MISO has identified, and as we discuss below, MISO has flipflopped on the underlying issue during the stakeholder process.

As ACP and CGA indicated in our initial letter on January 20, 2023, our organizations are not inherently opposed to any change in the DFAX.  Ensuring project deliverability to customers and assuring system reliability are shared goals.  Thus, our continued concern with the DFAX decrease from 20% to 10% is not driven by opposition to all changes in upgrade identification – rather, it is driven by significant uncertainty over whether the reduction in DFAX, and corresponding increases in upgrade costs, will actually solve what MISO purports it will.

MISO’s March 8 presentation[1] provided additional information on applying the 10% DFAX to a 2019 DPP Phase 3 study and showed an indicative number of constraints and affected projects based upon the reduction.  The slides also make reference to the number of unmitigated reliability overloads, but does not specify how many overloads would have occurred at different DFAX levels. MISO has still failed to 1) align the problem it is seeking to address with the solution it is proposing, and 2) meaningfully model the specific changes it is implementing throughout the interconnection process.

In the first instance, ACP and CGA urge MISO to clearly and specifically delineate the problem it is seeking to address through a potential DFAX change.  During the pendency of the DFAX conversation, MISO changed the rationale on the need for the DFAX reduction. As recently as 2021, MISO adopted a firm position that curtailment and congestion were economic issues, and not reliability issues.[2]  Accordingly, the current stakeholder process commenced with an evaluation of congestion as an economic problem. [3]  However, more recently, MISO has indicated that DFAX changes were to address reliability issues.[4]  The February 17 letter and March 8 presentation now provide what is largely an indicative economic response – showing the number of new upgrades that would be required at different DFAX levels, with some indication of costs for the Central and West regions in the 2019 DPP Phase 3.  However, despite MISO’s recent focus on the reliability implications of a DFAX change (and the reference to unmitigated reliability overloads in the presentation), there is no indication of how many reliability issues or violations of NERC criteria have occurred, or would occur in the future.  In providing indicative economic figures, the March 8^th presentation answers a different question than MISO is now asking.  

ACP and CGA ask that MISO clearly state whether it is viewing congestion as an economic or reliability issue, to provide specific details on which problems it is seeking to solve, and to provide more detailed information (discussed next) on how a DFAX reduction would or would not solve those problems.  If MISO is now viewing congestion as a reliability issue (a change from its late 2022 position when this topic was introduced), we ask that MISO provide data showing the implications of a DFAX change on the particular reliability overloads or violations.  

Second, we ask that MISO present analysis that reflects how the DFAX change will be conducted in practice.  The March 8^th presentation, while more detailed than any MISO presentation to date, risks excessively underestimating the financial impact this change will have on generators. The March 8^th presentation showed analysis applying a 20% DFAX to phases 1 and 2 of a historic DPP study, and only applied the 10% in Phase 3. However, the new BPM language applies the 10% to all three phases – this would cause higher impacts to more projects.  For ACP and CGA members to evaluate the efficacy of MISO’s changes, we respectfully request that MISO provide analysis reflecting how the DFAX reduction would be applied, consistent with the recent BPM changes.

ACP and CGA appreciate MISO’s initial analysis on these issues, and again offer support for changes that will demonstrably increase project deliverability and reduce any known or forecast reliability issues. We continue to find absent in MISO’s response any actual problem to be solved by lowering the ERIS DFAX.  We appreciate the clarification that MISO considers a reliability issue is behind changing the DFAX, but MISO has yet to provide any data indicating there are any reliability issues or violations of NERC criteria not already solved in MTEP or DPP studies. Lowering the DFAX has the consequence of creating barriers to interconnection and impeding the ability of states to procure new capacity resources and meet decarbonization goals, while creating financial inefficiencies that unnecessarily increase overall costs to load, without addressing the underlying causes of congestion. Moreover, MISO has not explained how this DFAX change comports with FERC’s cost allocation principles, in that ERIS interconnection customers must now bear incremental upgrade costs that are not at least roughly commensurate with benefits, given that ERIS is curtailable.  Meaningfully addressing economic congestion on the MISO system is more appropriately done through implementing the IMM’s suggestions, reinstating the MCPS process and studies,[5] and by implementing a regional TMEP process.  

Finally, we raise concerns that MISO has not followed its own stakeholder process or met its responsibilities under FERC Order 890. In fact, the process MISO followed in making this change is not posted on OASIS as required, nor does it adhere to standards of non-discrimination and good engineering practice. We encourage MISO to update its OASIS posting on BPM changes and cancel this unjustified BPM change that has been opposed by most stakeholders. 

Sincerely, 

Beth Soholt/Rhonda Peters, Ph.D.
Executive Director/Technical Consultant
Clean Grid Alliance 
570 Asbury St., Suite 201 
St. Paul, MN 55104 

Gabe Tabak 
Senior Counsel, American Clean Power Association
1501 M St., NW, Suite 990 
Washington, DC 20005