Transmission Developer Qualification and Selection. Planning Advisory Committee December 18, 2013

Transcription

1 Transmission Developer Qualification and Selection Planning Advisory Committee December 18, 2013

2 Transmission Developer Qualification and Selection: Prequalification what is this about? MISO s Prequalification process ask for information and data with regards to engineering, operations/maintenance, legal and financial. During Developer Selection, Transmission Developers who submit bids will also be asked to submit similar data bus also relating to that particular project. MISO s Prequalification process is designed to Demonstrate minimum qualifications necessary to be eligible to participate in the bid/selection process. 1

3 Transmission Developer Qualification and Selection: Order 1000 Requires Projects with Cost Allocation to be open to competition Applicable Projects Market Efficiency Projects Multi-Value Projects Non-Applicable Projects Baseline Reliability Projects Generator Interconnection Projects* Transmission Delivery Service Project Participant Funded ( Other ) * FERC Order 1000 specifically excluded interconnection upgrades from the compliance requirements 2

4 Transmission Developer Qualification and Selection: General Process Flow Current Process Prequalification Transmission Planning Process Board Approval of Projects Reevaluation (as needed) Developer Selection Request for Proposal 3

5 Timelines: General Process and Development Pre qualification application posted List of qualified projects BOD approves MTEP14 Developer bid submittal Developers selected RFPs posted Phase 1 Developer Pre qualification Design process/bpm Prequalify developers Phase 2 Request for Proposals Design Process/BPM Develop Project RFPs Phase 3 Developer Selection Design process/bpm Developer Selection Phase 4 Reevaluation Design process & BPM Reevaluation This is an annual process: Prequalification in Jan of each year RFPs posted 30 Days after each MTEP approved by MISO BOD 4

6 Timelines: Milestones Dates are for illustrative purposes only MISO posts prequalification application Jan 31, 2014 MISO notifies developers of qualification decision within 270 days of application submittal Dec 26, 2014 MISO posts Project RFPs Jan 1, 2015 MISO Notifies Selected Developers Dec 31, 2015 Pre qualify developers Developer prequalification submittal deadline March 31, 2014 MISO develops RFP s Developer Selection Developer Bid submittal deadline July 1, 2015 Developer preconstruction and construction processes Reevaluation This is an annual process: Prequalification in Jan of each year RFPs posted 30 Days after each MTEP approved by MISO BOD 5

7 Timelines: Prequalification Dates are for illustrative purposes only 2014 MISO posts prequalification application Jan 31, 2014 *If deficiency, MISO notifies applicant Apr 30, 2014 Year 1 MISO has 270 days to process, in Year 2, 180 days MISO notifies developers of qualification decision within 270 days of application submittal Dec 26, 2014 MISO posts qualified developers within 30 days of notification Jan 25, 2015 Pre qualify developers Developer prequalification submittal deadline March 31, 2014 **Developer responds to deficiency May 30, 2014 *MISO has 30 days from time of Application submittal to notify Developer if Application is deficient **Developer has 30 days to respond with additional data 6

8 Several Comments received from incumbent MISO Transmission Owners and other Transmission Developers. Some of the comments are suggested changes and some are questions related to the Application and/or BPM. The bulk of the comments were received the week of 12/9. We are diligently working to address them, but for many we wont have definitive answers at this point. Next Steps: We are developing an instructions sheet as a guide to the Application, this will address comments as well We will post updated responses in early January Will adjust BPM as necessary and repost Will adjust Application as necessary and repost 7

9 The requested information in the application may be quite extensive, are their options to submit it? We will allow information to be submitted on a data disc (dvd/cd). Due to IT security concerns, we are not allowing flash drives. The application asks for policies, procedures and other technical documentation that, as stated, can be quite extensive. We will allow submission of samples of this information with the caveat that MISO may ask for additional information as we process an application. Will MISO consider applications from entities not in the United States, e.g. Canada? Yes we will. There are no provisions in the tariff language prohibiting this, however, all other requirements must be met. 8

10 Based on the BPM language, what does a Transmission Owner need to submit? There is a section in this presentation that addresses this comment. Based on the BPM language, an existing Transmission Owner does not have to submit an Application? An existing, incumbent MISO Transmission Owner does not need to submit an Application if that TO only desires to bid on projects that are directly connected to its transmission system, as stated in Section VIII.B.b of Attachment FF. 9

11 Suggested changes to what MTEP projects qualify for ROFR Elimination, changes to tariff Module A Defined Terms. These changes require a tariff filing with FERC and will not be considered. Changing what type of projects qualify is a fundamental change to the policy MISO filed with FERC. Minor, non-substantive BPM language suggestions was submitted MISO will accept these as appropriate 10

12 BPM Section 2.1, bottom half of 2nd paragraph language regarding State ROFR Laws appears to violate FERCs statements in their Mar 2013 Order to MISO and should be deleted The BPM language is compatible with filed tariff language and MISO is waiting for FERC to make a final rule on this issue. This particular issue is out of scope for prequalification. BPM Section 3.4.1, Add the following language at end of last paragraph: Subsequent Application Fee will not be required if the Applicant can certify the previously approved information is correct and no material change is documented to MISO by an officer of the Qualified Transmission Developer s company. If any material financial or other changes take place within the Qualified Transmission Developer s business during the year, MISO must be immediately notified. No fee is required for renewal of Qualified Transmission Developers. The $20k fee is a onetime fee. MISO will consider whether to add language to the BPM. 11

13 BPM Section 1.3, References: what specific references is MISO referring to from the OATT and other BPM s? This is meant to be a general reference to Attachment FF and Transmission Planning BPM, and others as necessary. BPM 027 does not directly refer to nor use language directly from other BPMs. This is also boiler plate language found in other BPMs. MISO should consider including additional minimum criteria to the BPM to help clarify the Prequalification process MISO is reviewing this comment. 12

14 Please add BPM Section references to the Prequalification Application to aid in the completion of the application MISO will add such references from the BPM Please clarify which sections of the Prequalification Application are required and optional and under what conditions for A TO that intends to only bid on projects connected to its system A TO that intends to bid on projects outside of its system An entity not a current MISO TO and/or not currently owning transmission There is a section in this presentation that addresses this comment. 13

15 How is MISO going to use the optional data from Application section 2 and 3? A TO that intends to only bid on projects connected to its system A TO that intends to bid on projects outside of its system An entity not a current MISO TO and/or not currently owning transmission All information supplied will be taken into consideration to determine the qualification of a applicant to become a Qualified Transmission Developer. Will MISO use information from the Application to inform its decision making during the competitive bidding process The Developer Selection process has not been developed yet, and is premature to answer at this time. 14

16 Please clarify that the legal information requested in the Application Section 4 pertains only to matters relevant to construction, ownership, and maintenance of a transmission system, such as state or municipal transmission utility laws, and do not apply to employment actions or pending non-public matters, for example. MISO is reviewing this comment Please verify that the financial information requested in the Application Section 5 only requires public documents. If MISO requests non-public material, this should be considered optional for any applicant. Further, any non-public documentation, if required, must be assured confidentiality. MISO is reviewing this comment 15

17 BPM Sections & 1.5.2: The two definition sections in the BPM (the defined terms contained in Module A and new terms) have the potential to cause confusion, in particular as the definitions in Module A may change over time. It is recommended the BPM contain a section called definitions for those terms that are used in the BPM that not defined in the Tariff. MISO should indicate that any other defined term in the BPM that is not listed in the Definitions section has the meaning set forth in the Tariff. Further, include a clarifying statement that in the event of a conflict, the Module A definition will control. MISO is considering this. Tariff definitions were included in the BPM for the convenience of the reader. BPM Section 1.5.1: The New Transmission Line Facility definition needs more clarity. The referenced Tariff definitions are descriptive, but not exhaustive enough to provide a clear understanding of the delineation between new and upgrade. This is out of scope for the Prequalification process. It is also a tariff defined term and would require a new tariff filing. 16

18 BPM Section 1.5.1: The Open Transmission Project definition needs clarification that only the new facilities are eligible to be developed and owned by a non-incumbent. This is out of scope for the Prequalification process. It is also a tariff defined term and would require a new tariff filing. BPM Section 1.5.2: Please clarify that the Transmission Developer Application Fee definition to indicate whether there is a fee for the annual renewal that is different from the initial Application fee of $20,000. In addition, we recommend that the terms Transmission Developer Application Fee should be a defined term in the Tariff because it is stated in Attachment FF. There is no fee for renewal. This would require a new tariff filing. 17

19 BPM Section 1.5.1: The Selected Transmission Developer definition appears to only allow for Qualified Transmission Developers to be selected and not nonapplicants (i.e. incumbents) due to the reference to the definition of a Qualified Transmission Developer as an entity that submits an Application. However, Section B.2.6(b) of the July 22, 2013 Tariff language states: A Transmission Owner is automatically qualified to submit New Transmission Proposals and be selected as the Selected Transmission Developer for any Open Transmission Project where each group of contiguous New Transmission Facilities associated with the Open Transmission Project connects to an existing transmission facility owned by the Transmission Owner. The BPM definition should be corrected to conform to the draft Tariff and should include non-qualified Transmission Developer incumbents. MISO is reviewing this comment. 18

20 BPM Section 1.5.2: The final phrase in the definition of Open Transmission Project currently reads as and owned by a non-incumbent Transmission Owner. We recommend MISO clarify that phrase by replacing it with and the Selected Transmission Developer to ensure that it is understood that an entity much be selected through the MISO competitive bidding process to develop and own an open transmission project. This is a tariff defined term in Section of the tariff and would require a new tariff filing. 19

21 Attachment FF item VIII.B.7. states that: Qualified Transmission Developer Applicants must demonstrate and maintain an investment grade rating at all times to remain on the list of certified entities. While BPM Section states that: In the event the Qualified Transmission Developer Applicant does not have an investment grade rating Transmission Provider will consider additional information to evaluate its financial capability to construct the transmission facility in a timely manner, and to maintain and operate it reliably for the long term. The BPM requirements should be corrected to conform to the Tariff. BPM Section : Please confirm that an investment grade credit rating is required (of the Applicant or Applicant s Parent Company with a written guarantee from the Parent Co.). MISO is reviewing this comment. At the completion of the Application evaluation process, will a Qualified Transmission Developer be deemed qualified to bid on projects anywhere in MISO regardless of project size or cost? Yes 20

22 Please clarify how parent and subsidiary companies will be evaluated for the Qualified Transmission Developer Application. If the parent company submits the application would they be viewed in isolation or in conjunction with their subsidiaries? If a subsidiary submits the Application would a parent company, as well as associated subsidiaries, be treated as a single entity? Would an applicant be able to decide whether they are considered as isolated or conjoined? MISO is reviewing this comment 21

23 With regard to Joint Ventures, please clarify that two Qualified Transmission Developers would not have to pre-qualify the joint venture before submitting a bid. If the parties have separately been qualified they should certainly be qualified when working together. A Joint Venture can only be done by two or more Qualified Transmission Developers, but still has to be qualified before it can submit a bid to a project, per the tariff. Please clarify whether certification as a Qualified Transmission Developer is a requirement to be eligible for planning participation? If no, are there any requirements for planning participation? Participating the in the planning process is not a requirement for Prequalification, but is subject to consideration during the Developer Selection process. 22

24 Please consider allowing for more time than the 30 day minimum required by the Tariff for completion of the Application this first year due to the length of the template and uncertainty around the exact requirements. The tariff language states that the application deadline be no sooner than 30 days. MISO has not decided on a deadline, but is considering end of March to mid-april 2014, with an application posting of end of Jan Request that MISO complete Section 2.6 of the BPM on the Treatment of Confidential Data before the Application template is finalized. This section should clarify that the Application and all materials submitted with the Application are confidential and thus are treated in accordance with the appropriate sections of the MISO Tariff. MISO is reviewing this comment and expects to complete this Section prior to posting the application. 23

25 Is the Transmission Develop Application Fee non-refundable in the case that the Qualified Transmission Developer Applicant does not cure the deficiencies in its Application in the required time frame? Please clarify. Yes, the application fee will not be refunded if an incomplete application is not remedied during the cure period. And this is consistent with the MISO generator interconnection process. If a Qualified Transmission Developer terminates its status, but then seeks requalification must it include the $20,000 fee again? Please clarify. Yes, it must submit the fee again. 24

26 One of the enhancements suggested would be if any financial information changes take place during the course of the year to a Developer Application, the Applicant must notify MISO immediately. The applicant would provide MISO with the relevant information and MISO would decide if that applicant can remain a Qualified Developer based on the new information if previously approved as a Qualified Developer. Both the Tariff and BPM language specify that the QTD Applicant has an ongoing duty to provide an update to MISO as soon as reasonably practical should there be any material changes to an Applicant s (or relevant parent s) financial information submitted in compliance with Section VIII.B.7 after the application is submitted. 25

27 Developer Application: Required vs. Optional Data Section 2 is required for all applicants Section 3 is optional for all applicants For those that do not currently own, operate, and maintain any transmission, it is highly suggested Section 3 be submitted to help demonstrate to MISO your capabilities to build, operate, and maintain transmission facilities. 26

28 Developer Application: Required vs. Optional Data - Section 2 Required Data U. S. transmission line miles solely owned U. S. transmission line miles jointly owned U. S. transmission line miles operated and maintained - total U. S. transmission line miles operated and maintained as the NERC TOP U. S. transmission substations solely owned U. S. transmission substations jointly owned U. S. transmission substations operated and maintained - total U. S. transmission substations operated and maintained as the NERC TOP Total existing personnel - project implementation Total existing personnel - operations & maintenance Total man-years experience - project implementation Total man-years experience - operations & maintenance Gross investment in general plant to support project implementation and O&M Optional Data Owned transmission line miles by voltage Owned transmission line miles by state Operated & maintained transmission line miles by voltage Operated & maintained transmission line miles by state Gross investment in transmission line plant Substations owned by maximum voltage Substations owned by state Substations operated and maintained by maximum voltage Substations operated and maintained by state Total power transformer capability owned Gross investment in transmission substation plant Additional details on personnel and man-years of experience 27