In the March 6, 2024, meeting of the Planning Advisory Committee (PAC), MISO shared draft redline language for the Joint Targeted Interconnection Queue (JTIQ) Joint Operating Agreement (JOA).
Stakeholders are asked to review and provide feedback by March 20.
ENVIRONMENTAL SECTOR COMMENTS ON
MISO’S PROPOSED CHANGES TO THE JOINT OPERATING AGREEMENT WITH SPP REGARDING THE JOINT TARGETED INTERCONNECTION QUEUE (JTIQ) PROJECTS
The Environmental Sector submits these comments to MISO’s proposed changes to § 9.4 of the Joint Operating Agreement with SPP (JOA) that were proposed at the March 6, 2024 PAC meeting. The complexity of the JTIQ process is daunting and the Environmental Sector appreciates MISO and SPP’s dedication to solving seams challenges. Generally, the Environmental Sector’s position regarding JTIQ is (1) the projects are needed quickly, and (2) we need a process that will ensure generator developers will actually apply to interconnect. The comments below are intended to bolster the likelihood that these goals will be achieved.
JOA § 9.4.II.B.1. Capital Costs. While we believe the proposed language will likely function as a sunset provision for the 100%-to-generators / 0%-to-load cost allocation, we find it confusing. (Similar language has also been inserted into Att. FF § III.A.2.d.1.) Thus, we would request that the transmittal letter to FERC clearly state that the 100%/0% allocation is only applicable to this specific portfolio of JTIQ projects and any future portfolios would require a new cost allocation.
JOA § 9.4.II.D.4.a. Expanded Scope Study. JTIQ is intended to provide developers with more certainty regarding their costs. Having a firm estimate of costs early in the process minimizes the developers’ risk thereby incentivizing applications to interconnect. As currently drafted, it is unclear whether the risk will be sufficiently minimized to ensure full subscription for the JTIQ portfolio. Specifically, significant costs could be assigned to the developers through the Expanded Scope Study. To achieve the goals of JTIQ, it would be best if the costs assigned through the Expanded Scope Study were known in the Screening Phase of the DPP process, which is prior to significant “cash at risk” for developers. Providing this information early would also allow developers to drop out of the queue early if their project is not viable, thus reducing impacts to others in the queue. We understand that MISO (not SPP) will conduct the Expanded Scope Study for MISO projects, which should enable early disclosure of these cost estimates. Another option would be to put a cap on the costs that could be assigned to developers through the Expanded Scope Study.
Creating the 15% cost cap for the Supplemental Affected System Network Upgrades is precisely the type of mechanism that reduces risk for developers and increases the likelihood that developers will apply to interconnect to the JTIQ lines. The Environmental Sector fully supports the 15% cap in JOA § 9.4.II.E.3.a.ii.
JOA §§ 9.4.II.D.4 and 9.4.II.D.4.a each reference two subsections: “9.4.II.D.4.b and c”. However, we could not find those subsections in the draft JOA. Please explain.
Cost Overruns. As it stands now, developers with generation interconnection agreements (GIAs), are subject to the cost overruns of a third-party over which the developers have no control. The risk of such overruns creates additional uncertainty for the developer in addition to the risks discussed above. Challenges to the cost overruns in construction can only be accomplished through an after-the fact complaint at FERC, which itself is costly. We urge MISO to develop a check-and-balance system for significant cost increases over the estimate provided when the GIA was signed. The appropriate location for such an addition could be in JOA § 9.4.II.E.5 that requires the Transmission Owners to annually update their cost estimates.