By Amanda Durish Cook
MISO’s proposal to allow merchant HVDC lines to connect to its system is incomplete, FERC informed the RTO last week in a deficiency letter.
In its filing with the commission, MISO said it based the proposed merchant agreement on its existing generator interconnection agreement and procedures, but FERC on July 12 asked it to explain why it was appropriate to do so — among other questions (ER18-1410). The commission gave MISO 30 days to file a response.
The RTO’s proposal involves treating merchant HVDC as transmission rather than generation, and requires merchant developers to acquire MISO injection rights or a precertification that the system will be able to reliably manage the capacity and energy from proposed lines at the point of connection. (See MISO Plan Provides Tx Treatment for HVDC Lines.)
FERC asked MISO why the timeline and termination provisions for the proposed agreement differ from those in the GIA, given the RTO’s claim that the former is based on the latter.
The proposed HVDC agreement stipulates that if injection rights are not converted to external network resource interconnection service within three years of a line’s commercial operation date, MISO will terminate interconnection service. With the RTO’s GIA — which doesn’t include the concept of injection rights — an interconnection customer can extend its commercial operating date for up to three years without risking queue withdrawal. MISO had said the termination provision matched that of its GIA because in both cases, the “underlying agreement may be terminated if commercial operation is not achieved within three years of the commercial operation date.”
FERC also asked MISO to clarify whether it plans to simultaneously update its merchant HVDC connection agreement when it proposes to make changes to its GIA.
The HVDC agreement also includes a provision stating that transmission owners will be able to review any modifications to a connection facility that affects them, but FERC asked MISO how it would move forward with a HVDC connection request if a party to the connection agreement does not accept a modification.
The commission also asked MISO to describe the processes behind examining injection rights and its proposed merchant HVDC connection service study.
