Calpine Corp. (NYSE: CPN) argued on March 2 at the Federal Energy Regulatory Commission in defense of the Midcontinent ISO, saying MISO’s extension of a deadline to add new gas-fired capacity at Calpine’s Mankato power plant in Minnesota didn’t unfairly hurt new wind capacity competing in the MISO project queue.
Calpine, on behalf of its subsidiary Mankato Energy Center LLC, supported arguments that MISO filed in this matter on Feb. 18. “As explained herein, the Commission should reject attempts by certain intervenors, including a competitor of Mankato, to hijack this proceeding and promptly accept the Amended and Restated Standard Large Generator Interconnection Agreement (the ‘Amended GIA’) among Mankato, Northern States Power Company (‘NSP’), and MISO, that was filed on October 15, 2014,” Calpine added.
On Jan. 9, MISO made a filing in this proceeding that responded to questions posed by the commission’s Office of Energy Market Regulation regarding the extension of the Commercial Operation Date for Phase II of the project being developed by Mankato from June 1, 2007, to June 1, 2018. In that filing, MISO explained that the Commercial Operation Date extension for Phase II was processed consistent with the terms of the Standard Large Generator Interconnection Agreement among Mankato, NSP, and MISO’s predecessor, the Midwest Independent Transmission System Operator, dated November 2004 (called the “Original GIA”).
Nonetheless, Invenergy Thermal Development LLC and Invenergy Wind Development LLC, and subsequently, the American Wind Energy Association (AWEA) and Wind on the Wires (WOW), suggested that MISO acted improperly and/or granted Mankato unduly preferential treatment while discriminating against developers of wind facilities. In its Feb. 18 answer, MISO yet again explained that it acted properly in processing the Mankato interconnection request, and did so in accordance with the Original GIA, said Calpine.
Calpine said it vigorously disagrees with Invenergy’s and AWEA/WOW’s suggestions that Mankato was the beneficiary of any kind of unduly preferential treatment. As MISO has explained, Mankato had the right under Section 5.16 of the Original GIA to suspend the Commercial Operation Date for Phase II, which Mankato validly exercised. At the time of the suspension, Mankato was in full compliance with the terms of the Original GIA, including having already funded over 95% of the facilities required to accommodate the full output of both phases of the Mankato Project under the Original GIA, Calpine added.
Said Invenergy in its Jan. 30 comments in this case: “While Invenergy believes that there is no absolute bar in the Original GIA or in MISO’s Generator Interconnection Procedures (‘GIP’) to an extension of the COD for eleven years, MISO failed to follow the proper procedures in changing the COD here. Specifically, MISO failed to evaluate whether the revised COD would constitute a Material Modification under the Original GIA and the MISO GIP. Accordingly, Invenergy requests that the Commission specifically seek further explanations from MISO and also generally clarify the applicability of Section 2.3.1 of the Original GIA and Section 3.3.1 of the MISO GIP in processing requests for COD extensions. MISO also should be required to show that MISO has applied its practices consistently to developers of generation projects in MISO, or that Invenergy and others developing generation projects in MISO have not otherwise been harmed by MISO’s practices.”
Said a Feb. 3 letter from AWEA and WOW: “AWEA and WOW believe the protest filed by Invenergy Wind Development LLC and Invenergy Thermal Development LLC (together, ‘Invenergy’) in this docket raises a number of outstanding questions about MISO’s administration of its interconnection queue and its practices related to COD extensions. The flexibility extended to Mankato in the Amended GIA, for instance, appears at odds with MISO’s recent strict efforts to terminate Generator Interconnection Agreements (‘GIAs’) or reduce the interconnection capacity granted therein with respect to wind-powered generation projects that are not developed in accordance with the applicable GIA schedule, terms and conditions. AWEA and WOW would be concerned to the extent that MISO is giving preferential treatment to certain interconnection customers and not following its Tariff and the terms of its standard GIA and generation interconnection procedures (‘GIP’). AWEA and WOW encourage the Commission to seek further specific information from MISO to ensure that MISO is treating all interconnection customers in a nondiscriminatory and transparent manner and so the industry can have clear guidance and an understanding of how MISO processes its queue and generation interconnection.”
Notable is that the Minnesota Public Utilities Commission on Feb. 5 approved Northern States Power to buy capacity from the Mankato expansion project, and that Invenergy failed to make the cut in that proceeding with a bid to supply capacity out of an expansion of its Cannon Falls gas-fired plant in the state.
Under this GIA, Calpine at Mankato has approval for a 922 MVA facility, rated at 682 MW Summer gross and 757 MW Winter gross and 667 MW Summer net and 740 MW Winter net. This facility is composed of three units in a combined cycle rated at 226 MVA for combustion turbine generator no. 1, 226 MVA for combustion turbine generator no. 2 and 470 MVA for the steam turbine generator. Phase 1 involved the installation of the first 226 MVA combustion turbine generator and the 470 MVA steam turbine generator. Phase 2 consists of installing the second 226 MVA combustion turbine.