EDF Renewables (EDFR) appreciates MISO and PJM’s efforts to update their JOA to align with current MISO and PJM study procedures, incorporate relative queue priority, and clarify certain elements of the coordination between the two regions that had been absent in the prior version of the JOA. We generally support the intent of the revisions and the majority of the specific edits. There are, however, a few specific comments in certain areas of the JOA that we would like to address in these comments, as noted below:
- Section 9.3.3.3.iii may be the appropriate section of the JOA to include any related language to the sub-bullets below:
- At times in the past, the assumptions going into the Affected System Study reports have not been clearly indicated. It should be clearly required in the JOA that the AFS reports detail which version of the study procedures (BPM-015 or Manual 14 series) is being followed.
- Ideally, the Affected system should NOT change study methodology after changing its study procedures mid-cycle but rather wait until the next cycle with the affected system begins.
- If for some reason this is not agreeable to MISO and PJM, then any changes that have been made since a prior iteration of the study was provided should be clearly noted in the executive summary of the report and fully documented in the appropriate portion of the study report. This is a critical inclusion so that interconnection customers can fully understand the methodology used to produce the study results and cost allocation provided in the report.
- PJM and MISO should document how Affected System costs factor into the Readiness Deposit calculations and Milestone M3 and M4 payments. Presently, it is our understanding that MISO is NOT factoring in any identified upgrades on the PJM system into these calculations, but PJM is doing so. EDFR’s opinion is that these payments should only incorporate expected costs for mitigations on the host system since a project may forfeit a portion thereof if it were to withdraw, but there is no mechanism for those forfeited costs to go to fund upgrades on the Affected System
- 9.3.3.j. Why is it not possible for the PJM to collect the deposits from MISO for the Affected System Facility Studies as is done vice versa? Typically, MISO study deposits are much in excess of what is ultimately spent which should in many, if not most, cases cover any costs incurred by PJM to run their Facility Studies for MISO projects with impacts on the PJM system.
- 9.3.3.g.vi.
- The current proposed language should be edited as per below. Uncompleted Network upgrades do not always result in limited operation. Additionally, this paragraph reads as if it were a one-shot deal, without any later updates. Is this the intent?
- It should be added that upgrades be identified as contingent facilities in the Affected System Impact Study reports so that interconnection customers know whether or not the identified Network Upgrades may have an impact on exposure to limited operation.
Any MISO interconnection project relying on those Network Upgrades identified by PJM Affected System studies shall may have limited injection rights until those Network Upgrades are placed into service. Upon request, in accordance with the Interim Deliverability Procedure outlined in PJM Manual 14H, PJM shall determine the necessary injection limits (if any) associated with the MISO Interconnection Request that will be implemented in Real Time until the necessary upgrades identified through PJM’s Affected System studies are in-service.
- The summary presentation given at the IPWG (on slide 13) indicated that, as part of the transition plan, MISO and PJM will provide a non-binding, information only ‘Optional Study’ to demonstrate results for TC1 and DPP-2021 cycles. Will these results be reflected in the next phase of the study reports issued for TC1 (phase 3) and DPP-2021 (phase 2), and will the AFS costs identified in these studies factor into the projects’ qualifying for PJM’s Adverse Study Impact or MISO’s Penalty-Free Withdrawal refunds of Readiness Deposits or Milestone Payments? EDFR strongly recommends these results would factor into those calculations. To not be provided this opportunity if very large costs are anticipated would be quite problematic. Aren't some of these studies already in process?