IPWG: Generation Replacement Process Enhancement (PAC-2023-4) (20240312)

The Missouri Joint Municipal Electric Utility Commission d/b/a Missouri Electric Commission supports the Generation Process Enhancement proposal submitted by Alliant.

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

MPW would continue to opine that language directed at electrically approximate POIs at equivalent voltage levels seems better suited to the intent of reducing interconnection costs via tie line need mitigation than connecting at a different voltage level.

The additional guardrails are thoughtful, and the shift factor test seems appropriate to ensure local adjustments don't flow beyond a few busses to the greater system.

Thank you,

Greg

Savion, LLC (“Savion”), a Shell Group portfolio company, is an industry-leading utility-scale solar and energy storage project development company. Savion appreciates the opportunity to provide input on “Generation Replacement Process Enhancement (PAC-2023-4)”. Savion would like to request further clarification on the following topics prior to further considering support for this request.

• • • Savion is concerned with how queue priority is established when studying replacement generation. If a DPP cluster study has already started but takes 18 months to complete, can a gen replacement customer receive their final study result prior to the DPP Cluster Study completion? If yes, we believe this is akin to queue jumping and could alter the study result of GI customers in the Cluster Study if not studied at the same POI as the original generator.
    • How is MISO planning on implementing the new study replacement process? Will it be on similar timeline and duration as the DPP cluster studies? If generation replacement has a different process, there could be scenarios where a generation replacement project may have an advantages  For example a project could utilize an open bay position if they decide to move to a different POI. For instance, MISO DPP 2024 is not yet open; however, MISO allows the generation replacement process to start and the existing generator decides to move to a different POI where there is only one position available, now projects entering on DPP 2024 cycle would no longer be able to request the same POI since the generator replacement took the only position available. This simple example shows that the generation replacement could be in advantage if the process does not follow the dates as DPP cycles.
    • Will MISO tender the replacement generation the same form of GIA that is given to DPP customers? If so, will replacement gen be allowed to exercise the same COD delay rights that DPP customers are subject to? The expectation is that generation replacement facilities are supposed to reach COD within 2 or 3 years after the original gen has officially retired. It would be problematic if replacement gen are allowed to go beyond that 3-year expectation by exercising the COD extension allowed in the normal GIA.
    • Besides the DFAX change criteria, MISO should implement a no-harm test. Please see example below:
      • Existing POI - DFAX = 10.1% (Constraint on 138kV line) . New POI (2 buses away) - DFAX = 9.9% (Not a constraint on 138kV line). Change = 0.2% (meets criteria)
      • This would have an impact on the cost allocation. The project in the New POI would not participate any longer on the cost allocation as they do not meet the DFAX criteria. Now other projects that impact the same constraints will see its costs increase. Therefore, even if they do not meet the DFAX criteria, the move to the new POI is causing a harm on other projects. We would strongly recommend to add a no-harm test to ensure existing projects are not affected by this change.

Entergy Operating Company Feedback on the Generation Replacement Process Enhancement Relating to a Change in POI

March 28, 2024

In the March 12, 2024, meeting of the Interconnection Process Working Group (IPWG) stakeholders were invited to comment on a Generation Replacement Process Enhancement proposed by a group of Stakeholders, providing for a Change in POI.  Specifically, feedback was requested on "any additional enhancements considered necessary to proposed guardrails, reliability analysis and generator impact assessment included as part of the requested process enhancement."

The Entergy Operating Companies (Entergy) appreciate the additional safeguards included in the proposal presented at the March 2024 IPWG.  These enhancements to the original proposal provide appropriate guardrails to ensure that the Generator Replacement it is truly not impactful while addressing the issue the stakeholders have raised. 

Some flexibility in the Replacement Process makes sense, as it is not always possible to replace an existing generator at the exact same site due to land use and access constraints. While the original proposal was too broad; the updated proposal seems to appropriately balance the issues and provide a good roadmap for how a change in a POI should be evaluated in an interconnection study.

With the inclusion of the proposed changes, Entergy supports the proposal, provided that it is clear that the additional requirements proposed only apply if the replacement generator is seeking to interconnect at a different POI than the retiring generator. For example, a replacement at the same-POI should not have to have to pass analysis that includes additional queued generation.

These comments are submitted on behalf of the Solar Energy Industries Association (SEIA).

SEIA thanks MISO for the opportunity to comment on Alliant Energy’s Generation Replacement Process Enhancement Proposal (PAC-2023-4). Alliant’s Proposal is unjust, unreasonable, unduly discriminatory, and preferential on its face and will give replacement projects selecting a new Point of Interconnection (POI) the ability to circumvent MISO’s Interconnection Queue and Definitive Planning Process (DPP). This would allow entrenched market participants with replacement projects requesting a new, optimal POI to jump new Interconnection Requests in the queue through a shorter pathway to Generator Interconnection Agreement execution.  

Alliant’s presentations to the IPWG indicate that its proposal would allow generation owners to request new, optimal POIs and “provide[] a certified study report on impacts to the system,” which are subsequently reviewed by MISO and impacted Transmission Owners. This shifts study responsibility from the Transmission Provider (as in the DPP case) to the Interconnection Customer and allows the Interconnection customer to forego the DPP cycle. This is significant as MISO has recently seen large queue volumes create study delays during the DPP and increased uncertainty for projects remaining in the queue. MISO has yet to complete DPP Phase 1 for the DPP-2022 cycle for all regions and DPP Phase 1 for the DPP-2021 cycle for the central region. These delays are mainly due to factors on the MISO/Transmission Owner end and beyond the Interconnection Customer’s control. Id. Exempting Interconnection Customers with replacement projects seeking a new POI from the Queue and DPP and allowing self-performed studies will allow these customers to receive quicker accreditation under MISO’s Resource Adequacy construct and realize capacity sales. 

Alliant’s proposal will also likely put new Interconnection Requests at a significant competitive disadvantage due to higher costs associated with the Queue and DPP that replacement projects for new POIs can avoid. For instance, Interconnection Customers using the Generator Replacement Process must submit a $60,000 study deposit. This is significantly less than the costs/payments associated with the DPP, which are based on the MW size of the Interconnection Request. Moreover, while Alliant asserts that the study process would ensure that requests for a new POI are “neutral” to other generators (e.g., generators who are already interconnected), relocation of a POI may result in increased Network Upgrades for projects in the queue. This could also lead to additional DPP delays, as MISO and Transmission owners are required to refine study models after replacement projects receive MISO approval for a new, optimal POI.

EDP Renewables (EDPR) appreciates Alliant Energy’s effort to revise their generation replacement proposal, but upon careful review, the changes to the way projects would be studied will result in inequities in the interconnection queue. 

Alliant revises down the DFAX to 5%, however this still allows impacts to appear in its system impact analysis.  For example, a significant portion of MISO Transmission Owners use Local Planning Criteria (LPC) to assess the cost responsibility of Network Upgrades.  To truly demonstrate no harm, all LPCs need to be considered as part of this assessment.  The proposal also fails to address impacts to Affected Systems, sub-transmission, and operations that are normally part of the DPP process. 

The proposal still fails to address the increasing supply chain issues that Transmission Owners are experiencing on equipment such as circuit breakers and control houses.  This proposal allows a subset of projects to bypass the interconnection queue and would grant an unfair advantage by jumping to the front of the line for that equipment, further delaying all other projects the ability to accelerate through the queue.  This discriminatory treatment needs to be addressed as part of any replacement proposal.  

In addition, Alliant argues that a retiring voltage could act as a lead line to another transmission lines when replacing generation, however a change in connection to a different voltage level can create different flows on the system and would require different contingency studies.  As a result of the voltage changes and new studies required, this is more like a new interconnection request than a replacement generator request.

EDPR remains open to evaluate opportunities to create efficiencies in the generation interconnection process, but like numerous other stakeholders who shared concerns, we find the Alliant proposal too problematic to support.

Great River Energy and ITC appreciate Alliant’s review of stakeholder feedback on their proposal and the adjustments including additional “guardrails.”  While some of the concerns have been reduced with these additional limitations, we have some concerns that the fairness issue discussed during prior IPWG meetings is still not adequately addressed. The ability for the replacement project to move to a different voltage interconnection level in addition to two stations away could allow for the new POI to be located a considerable distance away from the original POI and introduce Network Upgrades at the POI to accommodate the change. 

Regarding the fairness issue, the inclusion of DPP queued generator projects within two stations of the replacement generator’s current POI into the replacement study models is a step in the right direction. If the replacement generator is moving to a new POI, the modeled queued projects should also be considered in the area near the new POI as well.  There is also the question of how and when does the replacement generator make it into the ongoing DPP study models.  There is some concern that these changes could open another avenue for Interconnection Customers to question the validity of the DPP study results.

There may be a need for clarity on defining the two stations; if the replacement generator is moving to a different voltage, that should be considered station one, then the maximum the POI could change beyond that would be one station away from the higher voltage bus.  POI moves to a new voltage within the existing substation potentially can cause some system issues due to the risk to loadings on the system as energy will move along the path of least resistance.  Moving to a substation or two away on a higher voltage again could cause additional loading issues based on again energy flowing to the path of least resistance.  Finally, connecting to the grid at a location other than the original POI will require new system contingencies to be developed along with the determination of the consequences of the change.  Each of these risks of loading changes is currently not an issue for the existing POI.

We also have concerns that the proposal does not yet address the contemplation of potential Network Upgrades to Interconnection Facilities to accommodate a change in POI.  For example, if the POI is moved to another existing station, a breaker would likely need to be added to expand the Network station.  Would there be a limit to how substantial these upgrades could be? Notwithstanding, recovery of the costs of these types of Network Upgrades are also a concern.  There are differences among regions on how costs are recovered that could be impactful.

Great River Energy and ITC acknowledge that Alliant is continuing to work through study metrics that could reduce/alleviate the fairness concerns identified.  In general, we support a plan that has clear metrics that supports further defining electrically equivalent from an impact from the Transmission System perspective and directly addresses the cost recovery issues.

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 support Alliant’s revised generation replacement process enhancement proposal as a flexible means to interconnect new generation resources in a quicker and more efficient manner than progressing through MISO’s interconnection queue. Alliant’s proposal is warranted because the generation owner has already paid for the network upgrades to the existing point of interconnection and because MISO’s current resource adequacy landscape cannot afford long delays in the generation replacement process.

Alliant’s revised proposal includes additional guardrails that attempt to alleviate stakeholder concerns. We believe that Alliant has effectively addressed several stakeholder concerns, but we have a few recommendations to ensure the proposed “no harm” tests are sufficiently robust. We recommend that Alliant and stakeholders explore additional guardrails including the qualified change analysis performed by MISO and limiting the new resource’s ability to move to a maximum of two busses away. 

We are supportive of analyses to check for short circuit, voltage, and thermal issues.

We would also find additional clarification helpful regarding:

• Whether the proposed two-substation limit includes distribution or transmission substations;
• Whether there is a technically sound limitation rooted in mileage that could be added to the two-substation limit, given that some substations have considerable distance between them;
• Whether this proposal would require additional language related to securing site control at a new interconnection facility; and
• The process for determining whether a replacement generator impacts the queue after DPP1 in a study process akin to the DPP System Impact Study.