The Midcontinent ISO filed with FERC an unexecuted Generator Interconnection Agreement with Geronimo Huron Wind and International Transmission Co. (ITC Transmission) for a 100 MW wind power project in Huron County, Michigan.
“Huron Wind is asking MISO to file the GIA unexecuted because it objects to Interconnection Customer Milestone No. 5 in Appendix B,” said the filing. “This milestone requires the Interconnection Customer to make a payment of $4,166,000 by August 1, 2015, which represents the full cost of long lead time items including a 345/120 kV transformer. It is not reasonable to require Huron Wind to pay the full cost of the transformer and other long lead-time items (on top of the $3,114,000 payment required by Section 11.5 of the GIA) in August 2015. Rather, the $4,166,000 payment should either be required at a later date or at least broken into smaller payments (e.g., three payments of one third of the full amount).
“ITC should not need to receive full payment for the transformer and other long lead time items by August 1, 2015 in order to achieve the In Service Date of November 15, 2016. Procurement of such items involves down payments for a fraction of the total cost with no risk of cancellation being borne by ITC. Further, ITC currently has a spare 345/120 kV transformer that could be used for this project if there is a slight delay in acquiring the new transformer. Finally, Huron Wind is willing to bear risk and work with ITC on timeline and contingent relay solutions if they are necessary to make the existing In Service Date feasible.
“Maintaining the existing 2016 In-Service Date is critical to Huron Wind in light of the pending expiration of the safe harbor for federal Production Tax Credits for wind energy on December 31, 2016. Huron Wind submits that this dispute could be resolved by building flexibility into the payment/construction schedule. If MISO and ITC would agree to a revised payment schedule for the transformer and other long lead time items, while also holding the In Service Date in place or moving it modestly to account for up front delays, the project could move forward. Significant time is still available to begin construction of the Network Upgrades in the spring of 2016 as has always been planned.
“During the negotiations of the GIA, ITC informed Huron Wind that the November 15, 2016 In Service Date was contingent upon ITC receiving the first milestone payment pursuant to the terms of the GIA by July 1, 2015. Huron Wind has, however, failed to make the first milestone payment or any other payments pursuant to the GIA. ITC cannot begin construction of Network Upgrades until the first milestone payment, as defined in the GIA, is received from Huron Wind.”
The project would interconnect at the Harvest Wind Tap Point on ITC’s new Harvest Wind Tap Point-to-Grassmere 120-kV transmission line. The Collector Substation for the project will be located about five miles from the point of interconnection.
The maximum net electrical output will be 100 MW as measured at the Point of Interconnection. The wind farm will consist of 50 Vestas V100 2.0 MW wind turbines. This is called the Apple Blossom Wind Farm project.