IPWG: Attachment GGG Improvement (PAC-2024-6) (20241203)

Thank you to the MISO team for taking on this topic; we know Merchant HVDC (MHVDC) projects are not commonplace and therefore are more difficult to pay close attention to.  With that said, there are a few MHVDC projects that plan to integrate with the MISO system in some way and at some point and we believe reforms to the guiding documents is warranted. 

Pattern Energy is developing the Southern Spirit Transmission Project (SST Project) which will be the first point-to-point HVDC system that connects the ERCOT grid to the Eastern Interconnection including a connection into MISO South with Entergy Mississippi.  Our comments are intended to be more holistic in how HVDC projects should be able to interact with energy and capacity markets in addition to how to advance study work for these important infrastructure projects.

Topics and Feedback

General Prioritization Feedback – Pattern is generally aligned with focusing on the Attachment GGG application / process as the first-tier priority over other matters in addition to development of one or more HVDC-specific BPMs.  We do believe that an initial approach may be more helpful in charting a path forward that focuses on outlines of what’s important and therefore needs to be included in a given aspect of these changing documents.  For example, if one intention of updating Attachment X for MHVDC projects is to clarify what studies are part of Attachment GGG and what studies are part of Attachment X, that feedback should be made available in the form of an outline sooner than the next 16 months so that active MHVDC projects are clear as to what is expected.  Thereafter, documenting the updates to the relevant documents can advance under more reasonable timelines that can be supported with MISO’s limited staff resources. 

A similar request is made as it relates to Module B changes given the significant delay in making those changes as “Third Tier” (see below). 

HVDC BPM Creation – Pattern believes it is a great idea to have a MHVDC-specific BPM(s) (or even HVDC-specific BPMs which are agnostic to whether such facilities are “merchant” or not).  BPMs help with implementation of Tariff language including specifics related to study requirements and we believe an HVDC BPM(s) will ensure consistency and conformity.  Will the IPWG be the venue for development of this BPM(s)?

MHVDC Application Updates – MISO’s Attachment GGG application does not currently offer rights to withdraw energy from the MISO market.  This is an important update that should be made in the near-term along with a one-time ability to update active MHVDC Applications with designation of withdrawal rights, if any.  Additionally, allowing the use of the Module B Transmission Service processes to advance study work for MHVDC projects that value the use of transmission service in addition to, or as a replacement to, injection and/or withdrawal rights is worthy of incorporating into the MHVDC application process.

Module B Updates – Pattern would like to understand how changes to Module B would be “third tier” (next 24 months) if updates to the MHVDC application process (to include the option to utilize Module B Transmission Service as a means to interact with the MISO markets) is a “first tier” matter.  In effect, this mismatch in “tiering” of Module B updates vs. MHVDC Application updates creates a risk of “purgatory” whereby MHVDC projects that wish to leverage Module B cannot do so (even on paper) and therefore the only “real” option for MHVDC projects to advance is the existing Attachment X process.  Pattern requests that MISO create an outline for the scope of changes that are contemplated in Module B and commit to advancing those modifications on a target timeline so that project developers have a game plan and can continue to advance their developments even if their Attachment X requests are terminated.  Additionally, Pattern requests that MISO allow transmission credits to accrue for upgrades that are identified and funded under a Transmission Control Agreement (e.g., “necessary upgrades”) that can therefore be used to offset costs associated with transmission service.  This will likely require updates to Attachment GGG or other relevant MISO OATT language.

“Market Import Service” Option – In the context of interacting with the MISO markets, Pattern encourages MISO to consider an energy import option similar to SPP’s “Market Import Service” which is a way to schedule energy into the market as a price-taker subject to the SCED and real-time contingency analysis (RTCA).  This allows schedules to flow from MISO’s neighbors similarly to transactions that can enter MISO’s system from its AC-connected neighbors today. 

E-NRIS and Capacity Value – Pattern’s SST Project is a “market-to-market” interconnector which may not have bespoke generators that interconnect to (or contractually transmit across) the SST Project facilities that terminate at its MISO Point-of-Interconnection.  As such, an “NRIS-type” of interconnection right may not be appropriate or warranted.  With that said, the geographic and “market” diversity that a controllable transmission asset (like HVDC) can provide access to is a capacity value which can be studied and developed into a “slice of system” construct to properly value these diversity benefits.  Although the IPWG discussions on MHVDC have not engaged specifically on capacity valuation, the idea behind E-NRIS does tie to capacity (which is what NRIS-qualified generators are) and therefore Pattern is raising these issues as important to engage on in the context of the interconnection rights product offering and in the context of Module B changes to allow MHVDC to provide the value to the market that is inherent in these flexible assets.

Site Control Requirements – Pattern appreciates that site control, as a readiness hurdle, is an important aspect for consideration.  With this said, the intention of more stringent site control requirements is to ensure MISO’s limited staff and consulting resources can focus on projects that are most ready in the spirit of a “first ready, first served” methodology.  It’s important to note, however, that MISO approves MTEP transmission projects that may not have a single foot of acquired Right-of-Way and therefore a more nuanced approach is most appropriate.  Pattern looks forward to engaging on a site control approach that properly balances the long runway and development risks of MHVDC projects with the limited resources available to advance study work and integrate into the Attachment X and MTEP planning processes.  One suggested approach may be to differentiate site control requirements for (Attachment GGG + Attachment X) MHVDC projects vs. (Attachment GGG + Module B) MHVDC projects. 

SREA provides the following comments regarding MISO’s presentation at the December 3rd IPWG which outlined their process for implementation of HVDC interconnection application reforms in Attachment GGG of the MISO Tariff. SREA is appreciative of the reforms MISO has agreed to implement and we feel that they are necessary to ensure fair treatment of HVDC facilities in the interconnection queue. Overall, we urge MISO towards comparable treatment of MHVDC facilities wishing to connect to the MISO system, and in that context we are deeply concerned about the pace that MISO has dictated for implementation of Tiers 2 and 3 of the reforms outlined in the presentation, which delays comparable treatment. 

However, we provide the following in answer to MISO’s questions they are seeking stakeholder feedback on:

• Which enhancements are recommended to be the highest or lowest priority, and why?

• Any suggestions for other perspectives on the improvements?

We urge MISO to consider allowing for limited operations to be a higher priority item that should be either implemented immediately, or elevated from Tier 2 to Tier 1. Given language already in BPM 015 related to Annual Energy Resource Interconnection Service (A-ERIS) / Quarterly Operating Limits (QOL) it should be fairly straightforward to implement for MHVDC in Attachment GGG. If for some reason there are policy specifics that do need to be hashed out in more depth for Attachment GGG, we believe these specifics are minimal enough to justify them being handled in the Tier 1 timeframe. Furthermore, we want to stress that there are material risks in delaying implementation on this issue. Delay creates a lack of clarity for generators wishing to subscribe to an MHVDC line being studied in the queue and an under-subcribed line can not only result in financial risk for the developer but also reduce the amount of capacity contracted to the line that is deliverable to the MISO system.  

Also in Tier 2, we have concerns regarding MISO’s effort around Necessary Upgrade Identification. It has been affirmed by FERC in ER22-477 that Necessary Upgrades are to be separate from GIP Network Upgrades (NU’s), but we need clarification to understand what this effort entails before deciding what priority it should be given. Broadly we have concerns that this effort may expand the definition of ‘Necessary Upgrades’ to GIP NU’s, limiting the funding flexibility for Transmission Connection Agreements. 

In terms of other perspectives on MISO’s proposed improvements, SREA urges MISO to examine closely where policy gaps can be filled readily, as with the limited operations issue, to expedite the process of implementation in Attachment GGG. The policy reforms are generally less complex than technical issues stated for the Tier 2 and 3 timelines, and in many instances, there are close parallels in the BPM and Tariff which can be adopted and implemented to ensure comparable treatment. With regards to more technical issues, we see potential for moving Modeling Specifications/Requirements into Tier 1, as it may relate to current procedures already detailed in BPM 015 or Attachment X which can inform modifications needed in Attachment GGG. 

Overall, we would like to express that we are appreciative of MISO’s efforts to revise Attachment GGG, which will enable more efficient interconnection of MHVDC, and increase transparency in TCA’s, but we believe that there are opportunities where MISO can move more quickly to implement their stated reforms. 

IPWG: Attachment GGG Improvement (PAC-2024-6) (20241107)

Invenergy appreciates the opportunity to provide our feedback to MISO’s Attachment GGG Improvement (PAC-2024-6) on which enhancements are recommended to be the highest or lowest priority, and other suggestions or perspectives on the proposed improvements.

https://cdn.misoenergy.org/20241203%20IPWG%20Item%2005%20Attachment%20GGG%20Improvements%20(PAC-2024-6)663272.pdf

Attachment GGG is part of MISO’s Tariff which pertains Merchant HVDC Transmission Connection Procedures (MHCP).

MISO presented on the topic of MISO’s workplan for MHVDC connection procedure improvements including:  MHVDC Applications, Application Modifications, MHVDC Studies, Transmission Connection Agreements, and Module B Updates.  Further, MISO prioritized each aspect into different tiers.  First Tier anticipated to take 8 months, Second Tier 16 months, and Third Tier 24 months.

Reprioritize TCA Limited Operations to Higher Tier One

As proposed by MISO at the November 2024 PAC, the TCA Limited Operations was prioritized as Second Tier taking up to 16 months.  We recommend that TCA Limited Operations be prioritized to the higher Tier One, given that the process already exists for generators under Attachment X and it would be simply be replicated in Attachment GGG. 

Seeking Comparable Treatment While Necessary Upgrades are Pending

Language already exists in the MISO tariff under Appendix H allowing generators to enter limited operations prior to their network upgrades being completed.  Merchant HVDC lines are simply requesting that this language or similar language be included in Attachment GGG, such that MHVDC projects can pursue limited operations as well.  

Appendix H is only two and half pages. For convenience, we have pasted the relatively small section below:

Appendix H to GIA Interconnection Requirements for Provisional GIA

Provisional Agreement

This GIA is being provided in accordance with Section 11.5 of the Transmission Provider’s GIP, which provides among other things, that an Interconnection Customer may request that Transmission Provider provide Interconnection Customer with a Provisional Generator Interconnection Agreement that limits the transfer of energy by Interconnection Customer commensurate with that allowed for Energy Resource Interconnection Service. Interconnection Customer requested Transmission Provider to provide a Provisional Generator Interconnection Agreement for limited operation at the discretion of Transmission Provider based upon the results of available studies (by Interconnection Customer and by Transmission Provider).

A Provisional Interconnection Study, the results of which are posted on the confidential portion of the Transmission Provider’s internet website, was performed by Transmission Provider in order to confirm the facilities that are required for provisional Interconnection Service and to require them to be in place prior to commencement of service under the GIA.

Interconnection Customer represents that the Interconnection Customer facilities (including Network Upgrades, Interconnection Facilities, Distribution Upgrades, System Protection Upgrades and/or Generator Upgrades) that are necessary to commence provisional Interconnection Service and meet the requirements of NERC, or any applicable regional entity for the interconnection of a new generator are in place prior to the commencement of generation from the Generating Facility and will remain in place during the term of the service. The requisite Interconnection Studies were performed for the Generating Facility. Interconnection Customer shall meet any additional requirements (including reactive power requirements) pursuant to the results of applicable future Interconnection System Impact Studies. Until such time as the applicable Interconnection Studies and any identified facilities are completed, the output of the Generating Facility will operate within the output limit prescribed in a future, if applicable, operating guide.

The maximum permissible output of the Generating Facility under Appendix A will be updated by Transmission Provider on a quarterly basis, determined in accordance with Section 11.5 of the GIP, by finding the transfer limit of energy commensurate with the analysis for Energy Resource Interconnection Service (“ERIS”). This study shall be performed assuming the system topology represented by the base cases used to calculate Available Flowgate Capability, as described in Attachment C of the Tariff, with dispatch and optimization algorithms posted on the MISO internet site and operation above those limits will be deemed as unauthorized use of the Transmission System and subject to provisions in the Tariff surrounding that use.

Use of interim operating guide

Implementation of interim operating guide, if applicable, will constitute an interim solution that will permit Interconnection Customer to operate the Generating Facility under conditional Interconnection Service until planned Network Upgrades are constructed. Any interim operating guide will be subject to the approval of Transmission Owner and Transmission Provider. Minimum requirements for an interim operating guide are as indicated below.

* Transmission Operator will have control of breaker(s) dedicated to the Generating Facility and will be able to trip the Interconnection Customer’s Generating Facility

* Protection schemes must be tested and operative

* Interconnection Customer will provide continuous communication capability with the Generator Operator

* Interconnection Customer and the owner of the Existing Generating Facility will enter into an operating agreement or similar agreement which designates, among other things, the responsibilities and authorities of each of the parties and shall be subject to the acceptance of Transmission Provider and Transmission Owner.

* A termination date consistent with completion of construction of Network Upgrades will be included as part of all operating guides accepted by Transmission Owner and Transmission Provider.

Interconnection Customer assumes all risks and liabilities with respect to changes, which may impact the Generator Interconnection Agreement including, but not limited to, change in output limits and responsibilities for future Network Upgrade and cost responsibilities that have not yet been identified on the direct connect Transmission System as well as all affected Transmission, Distribution or Generation System(s) including non-Transmission Provider Systems. Such upgrades will be determined pursuant to the Tariff and Policies in effect at the time of the Interconnection Studies.

Low Hanging Fruit - Utilize Existing Tariff Procedures for Generators

Leveraging existing language already in the tariff should be relatively straightforward.  In fact, after a review of the existing tariff language for limited operations for generators, one would not be able to differentiate much if any tariff language that would be unique to generators that could not be applied to HVDC. 

Timeframe for Abeyance of Complaint Proceedings are Coming to an End:

On April 3, 2024, pursuant to Rule 212 of the Commission’s Rules of Practice and Procedure, Grain Belt Express LLC (GBX) filed a motion to hold complaint proceedings in abeyance until December 31, 2024, absent a further filing by GBX, to allow for the possible resolution of the matters raised by the complaints through the Midcontinent Independent System Operator, Inc. (MISO) stakeholder process.

On April 26, 2024, upon consideration, notice was given by FERC that GBX’s Motion was granted. As such, FERC will not take any action on these complaint proceedings until after December 31, 2024.

MISO has stated in the applicable docket that it will evaluate adding a limited operation option to its Tariff in a stakeholder process to be commenced in the second or third quarter of 2024.

While MISO did conduct a fourth quarter 2024 presentation on a proposed work schedule, that presentation does not represent meaningful stakeholder evaluation specific to limited operations. 

Invenergy acted in good faith in seeking FERC approve an abeyance in this instance. Invenergy reiterates the urgency of moving TCA Limited Operations forward for a stakeholder discussion to expedite this necessary tariff addition to provide transparency and certainty.   

Clean Grid Alliance Comments on Attachment GGG Merchant HVDC Improvements (PAC 2024-6)

Dec 17, 2024

Clean Grid Alliance appreciates the opportunity to comment on MISO’s presentation to the Interconnection Process Working Group on December 3^rd: 

https://cdn.misoenergy.org/20241203%20IPWG%20Item%2005%20Attachment%20GGG%20Improvements%20(PAC-2024-6)663272.pdf

MISO has asked stakeholders: 

• Which enhancements are recommended to be the highest or lowest priority, and why?
• Any suggestions for other perspectives on the improvements?

MISO has categorized improvements into 3 tiers as noted in the presentation at the ink above.   

Clean Grid Alliance strongly urges MISO to prioritize MHVDC limited operation/AERIS/QOL as the first thing it works on in Tier 1. To begin with AERIS/QOL should seemingly already apply, especially for any injection rights obtained through Attachment X, as it is very straightforward and should not require any additional work. However, if additional work is required, it should be the very first thing MISO works on in Tier 1 due to the significant impact it has in regard to market transactions. Any lack of clarity around AERIS/QOL will delay generator subscriptions on MVHDC lines that are advanced in the MISO queue or with executed interconnection agreements. 

Overall, more information would have been helpful in the presentation to better understand what MISO feels needs to be addressed in each topic, but we generally agree that any policy development around modifications to the MHVDC application should be a priority (after limited operation/AERIS/QOL). MHVC projects take longer to develop than generator interconnection projects and may require flexibility to modify the original application while in that process. 

In regard to the Module B edits for TSRs, and “clarification of Necessary Upgrades”, CGA would appreciate some detail on what exactly MISO plans to address under each of these topics. It is challenging to provide input and prioritization on the proposed efforts, without better understanding the purpose, intention, and ultimate goal of those efforts. 

Clean Grid Alliance Comments on Attachment GGG Merchant HVDC Improvements (PAC 2024-6)

Dec 17, 2024

Clean Grid Alliance appreciates the opportunity to comment on MISO’s presentation to the Interconnection Process Working Group on December 3^rd: 

https://cdn.misoenergy.org/20241203%20IPWG%20Item%2005%20Attachment%20GGG%20Improvements%20(PAC-2024-6)663272.pdf

MISO has asked stakeholders: 

• Which enhancements are recommended to be the highest or lowest priority, and why?
• Any suggestions for other perspectives on the improvements?

MISO has categorized improvements into 3 tiers as noted in presentation at the link above.

Clean Grid Alliance strongly urges MISO to prioritize MHVDC limited operation/AERIS/QOL as the first thing it works on in Tier 1. To begin with AERIS/QOL should seemingly already apply, especially for injection rights obtained through Attachment X, as it is very straightforward and should not require any additional work. However, if additional work is required, it should be the very first thing MISO works on in Tier 1 due to the significant impact it has on market transactions. Any lack of clarity around limited operation/AERIS/QOL will delay generator subscriptions on MVHDC lines that are advanced in the MISO queue or have recently completed an interconnection process. 

Overall, more information would have been helpful in the presentation to better understand what MISO feels needs to be addressed under each topic, but we generally agree that any policy development around modifications to the MHVDC application should be a priority (after limited operation/AERIS/QOL). MHVC projects take longer to develop than generator interconnection projects and may require flexibility to modify the original application while in that process. 

In regard to the Module B edits for TSRs, and “clarification of Necessary Upgrades”, CGA would appreciate some detail on what exactly MISO plans to address under each of these topics. It is challenging to provide input and prioritization on the proposed efforts, without a better understanding their purpose, intention, and ultimate goal.