Richard Seide
Principal
Energy Market Consulting Partners LLC
Tel: 513-891-5684
Cell: 513-382-8571
[email protected]
April, 28, 2014
Mr. Vikram Godbol
Sr. Manager
Transmission Access Management
Midcontinent Independent System Operator
720 City Center Drive
Carmel, IN 46032-7574
Re: Plan for Achieving Conditional GIAs
Thank you for the opportunity to provide input on this matter. Please note that the
comments which follow are my own and should not be attributed to any MISO member,
market participant, or generation queue party.
I am writing in support of MISO’s proposal for granting Conditional GIAs which was
presented to stakeholders during the Interconnection Process Task Force (IPTF) on
April 21, 2014. Specifically MISO has put forth a plan to enable near term
interconnection service subject to completion of a customer funded Optional Study to be
followed by the tendering of a Provisional GIA for execution.
In the Optional Study MISO proposes to enforce the 1627 limit on the MWIX interface.
MISO will then perform Quarterly Operating Limits studies to determine injection
restrictions (if any) until a new, permanent GIA is executed. The intent of the proposal
is for interconnection to be permitted prior to energizing the Lacrosse-Madison Multi
Value Project (MVP) Line in Wisconsin.
MISO’s plan as set forth in the IPTF meeting handout permits generators that qualify for
Production Tax Credits (PTCs) to be processed under the MISO Tariff in a fair and
efficient manner, without subjecting those same interconnection customers to undue
delay and uncertainty. The plan also assures that the reliability and security of the high
violated system is maintained in both planning and operational contexts.
Efficient processing of the generator queue has long been an objective of MISO in
various Queue Reform efforts approved by FERC. MISO’s current proposal is an
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extension of rules designed to permit generators that are “ready”, to move into
operations albeit on a conditional basis. Absent the ability of “ready” project to advance
in the queue, projects are frozen in a manner not unlike the conditions which prevailed
prior to Queue Reform.
During the IPTF on April 21, 2014 several developers spoke in favor of MISO’s proposal
from the meeting room and over the phone. The consensus view at the session was
that MISO’s plan is workable, and balances customer risk with concerns for system
reliability.
Finally under the Long-Term part of the proposal MISO sought stakeholder input on
modeling combined cycle gas generation during shoulder peak periods. MISO
proposes to dispatch combined cycle units at 50% of nameplate output in the shoulder
period instead of at 0%. While the proposal has merit MISO should clarify that the
change in output will not change the modeling procedure for simple cycle gas peaking
units. In other words the change is targeted at mid merit units.
Further, MISO should verify what level of activity mid merit gas units are committed and
cleared in the market on a regional basis. Here activity may vary from region to region
and MISO’s MTEP and interconnection planners should be cognizant of differences (if
any). Last, while the notion that low natural gas prices may automatically cause more
combined cycle dispatch commitments, the opposite is plausible also going forward.
Despite new production and pooling centers the natural gas market currently is
experiencing record low inventories which from a physical and adequacy standpoint
extends to modeling years in 2015 and beyond. In other words I urge checking
assumptions on fuel prices before changing dispatch patterns in generators models.
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