By Amanda Durish Cook
FERC on Monday approved MISO Tariff revisions allowing the RTO to gather more information about proposed energy resources before they enter the interconnection queue.
Key among the changes is a requirement that a developer provide clearer upfront information about who will own a generating unit once its clears the queue.
In its ruling, FERC agreed the changes will “provide greater clarity to interconnection customers and greater transparency to all parties in the interconnection process” (ER18–636). The new measures became effective March 1.
Under the new rules, interconnection customers must provide MISO upfront documentation of “legally binding relationships” with parties that may claim ownership rights to a facility during the interconnection process.
MISO said the change will reduce the time it spends confirming ownership changes and will be necessary only when an interconnection customer “reasonably anticipates” another entity may claim ownership rights. The documentation would be limited to “that necessary to confirm the legal status and relationship of the relevant entities,” the RTO said.
Interconnection customers associated with a project can sometimes change during the definitive planning phase (DPP) of the interconnection queue, MISO said in its filing. In those cases, the RTO must confirm the legal status and relationship between the original and newly designated interconnection customers, creating an “administrative burden … that hinders the ability of MISO staff to administer other aspects” of the DPP.
“Requiring documentation proving legally binding relationships with entities that the interconnection customer reasonably anticipates may claim rights under the interconnection request upfront in the interconnection request form will ease administrative burden if a facility changes ownership later in the interconnection process,” FERC said, adding the change will help expedite projects moving through the DPP.
The commission rejected EDF Renewable Energy’s protest that MISO didn’t justify its need for the additional detail and that the changes would give the RTO more information than it needed. The company alternatively proposed that interconnection customers provide MISO with documentation “confirming a legally binding status upon requesting a name change,” rather than at the outset of the process. FERC said EDF was conflating name changes with changes in ownership status.
The Tariff revisions also require interconnection customers to provide MISO with IRS W-9 forms; banking information (including for other companies that may claim ownership in a generating facility); GPS coordinates for the point of interconnection for a project; descriptions of the number of generators, inverters, and transformers involved in the interconnection request; and additional contact information when a customer uses an agent.
They also expand the service options listed on MISO’s interconnection request form, allowing customers to specify a net-zero interconnection service request for an existing facility with no increase in capacity; indicate whether a request should be considered for the RTO’s fast-tracked process offered to small generating facilities; and inform MISO when a request for network resource interconnection service is intended for an existing facility.
The new rules additionally stipulate that net-zero interconnection customers must attach a system impact study to their requests and provide MISO with all necessary data before generator interconnection agreement negotiations can begin.