MISO confirmed it will make a second bid to FERC to establish a temporary fast lane in its interconnection queue, this time limiting the process to a total of 50 generation projects.
The new, 50-project limit would stand to reduce the number of quarterly cycles MISO ultimately accepts in the expedited process. MISO also would limit the number of projects it studies per quarter to no more than 10.
FERC in mid-May turned down MISO’s proposed express lane, saying MISO failed to establish standards on which projects may enter based on resource adequacy needs and failed to control how many projects could line up for expedited treatment. (See FERC Rejects MISO’s Interconnection Queue Fast Lane.)
Previously, MISO planned to open up to 14 quarterly submission windows to an unlimited number of projects through the end of 2028.
“FERC gave us good guidance on what is necessary to refile,” Director of Resource Utilization Andy Witmeier said at a May 28 Planning Advisory Committee meeting when announcing the intention to refile.
MISO plans to submit a fresh proposal to FERC by June 6, which would request an Aug. 5 effective date. The RTO is forgoing a usual stakeholder comment period on edits to the refile.
Witmeier said the 50-project limit is based on PJM’s Reliability Resource Initiative and said FERC appeared to be “comfortable” with that figure. He also said MISO has been coordinating with the Organization of MISO States (OMS) and individual state regulators to put finishing touches on the filing.
MISO now would require that projects and their correlated resource adequacy needs be within the same local resource zone. Developers must submit the specific load addition or capacity shortage their project would address, with MISO publicly posting those associations.
The RTO also is stipulating that the interconnection service of the projects should not exceed 150% of an identified megawatt need.
Regulators now must “verify instead of notify” MISO as to how projects will meet a resource adequacy need, Witmeier said.
He said the new project maximum and regulator verification will eliminate the open-ended number of projects and better describe how projects will meet anticipated generating shortfalls.
“There are no real changes to the process. These are just guardrails and gaming requirements,” Witmeier told stakeholders.
Witmeier said the expedited process should wrap up sooner than it would have under MISO’s first proposal.
“It’s possible that we’re done by 2027 or late 2026. … I suspect we’ll have our 50 projects by the time 2027 comes into play,” Witmeier said. “We’re proving that this is not a new queue and will address immediate needs.”
Because of FERC’s initial rejection, MISO would accept project applications under a second try through Aug. 11 and kick off its expedited studies for the first cycle Sept. 1 instead of the originally planned late May.
Wisconsin Public Service Commissioner Marcus Hawkins contradicted MISO’s characterization that OMS is working in close collaboration with it on the revised filing. Hawkins said aside from previewing a MISO draft of the regulator verification of projects, “most of the proposal we’re seeing for the first time.”
“OMS really can’t work in a 14-day time period. That’s just not how we work. … It’s not possible to have OMS coordination on this new filing.” Hawkins said. He explained that decision-making in OMS involves multiple check-ins and bringing several parties up to speed on issues.
Witmeier said he understood the OMS board setup and agreed that scheduling obstacles would preclude the organization from full participation before the refiling target date.
Stakeholders said they worried that disparities among states’ methods for substantiating resource adequacy needs would result in expedited projects spread unevenly throughout the footprint.
Witmeier said it was possible a state would never justify a project for the fast lane while other states would recommend multiple facilities. He repeated several times in his presentation that MISO is not a resource planner.
Clean Grid Alliance’s David Sapper said he’s concerned about the 150% threshold beyond stated needs. He said such a large margin would be anti-competitive and discriminatory and could introduce network problems.
“It’s that margin that’s not balanced that could change import and export limits in ways that are not good for reliability,” Sapper said. He also said MISO’s in-zone requirement would unfairly elbow out suppliers from other zones.
“That’s a biggie. We need to think about this need determination,” Sapper said.
Sustainable FERC Project’s Natalie McIntire questioned why MISO would use interconnection service instead of a megawatt value to set the 150% threshold.
Other stakeholders said they didn’t see how the proposal wouldn’t again exclude Illinois’ and Michigan’s retail choice areas, where competitive markets, not vertically integrated utilities, ensure resource adequacy. MISO would open the fast lane to interconnection customers with power purchase or other agreements in addition to load-serving entities with self-supply acknowledgments and projects in the existing queue wishing to transfer to the express lane.
Finally, stakeholders asked if MISO would consider exceptions beyond the 50 projects.
“We certainly believe that this will meet our current needs and meet FERC’s requirements. Beyond that, we don’t see a need for extension,” Witmeier said.
It’s unclear if MISO’s project cutoff and documented resource adequacy requirements will be enough to quell clean energy groups’ discrimination complaints about the first proposal. The Natural Resources Defense Council, Sierra Club, Sustainable FERC Project and Union of Concerned Scientists were among the groups challenging the design the first time around.
Following FERC’s rejection, the Sierra Club said MISO’s “discriminatory plan” would have favored gas plants at the expense of the approximately 200 GW of wind and solar generation and battery storage currently in the MISO interconnection queue.
“It’s good to see FERC taking a deep look at extreme proposals like MISO’s here. Interconnection fast-track proposals … are fundamentally discriminatory, and the commission made clear that discriminatory tools should only be used to address the most severe emergencies. MISO failed to demonstrate such an emergency here, and its policy was not well tailored to meet one,” Sierra Club Senior Attorney Greg Wannier said in a statement.
Wannier said Sierra Club planned to engage in MISO’s stakeholder process to “address the serious concerns raised by commissioners and stakeholders and come back with a targeted solution.”
