By Amanda Durish Cook

CARMEL, Ind. — MISO is proposing near-term changes designed to speed up its interconnection queue as it confronts its largest-ever influx of potential generation projects.

The RTO plans to reduce the number of project studies occurring in the first phase of the definitive planning phase (DPP) of the queue and require customers to demonstrate ownership, lease interest or land rights on a project’s site before entering the queue, stakeholders learned during a May 15 Interconnection Process Task Force (IPTF) meeting.

MISO Director of Interconnection Planning Vikram Godbole said the proposal constituted “a small set of changes that will be very beneficial to the queue” and that the RTO began working on improvements to the queue last year after FERC accepted its redesign proposal. He said MISO and several customers have been meeting for months to discuss ways to expedite the RTO’s packed pipeline of potential projects.

Godbole said the changes are designed not to harm any existing interconnection customers. They come a month after FERC declined to order MISO to redesign aspects of its relatively new queue process but reminded the RTO of its duty to make a good faith effort to address a worsening backlog of projects. (See FERC Sides with MISO in Queue Design Dispute.)

100% Site Control

MISO is proposing to require interconnection customers to demonstrate 100% site control to the point of interconnection before entering the queue, scrapping the existing option that allows them to submit a $100,000 deposit in lieu of proof of site control. Just 25% of the projects entering the DPP in the April 2018 cycle demonstrated site control, with the rest electing to make the deposit.

The RTO currently requires a customer to demonstrate 75% of site control prior to entering the third — and final — phase of the DPP.

Godbole said the more stringent requirement should prevent unready projects from prematurely entering the first phase of the DPP. It would also prevent customers from submitting multiple, overlapping projects at the same development site, a recurring issue in the current queue, although Godbole declined to identify any specific instances.

“That is just not right, and we need to fix that,” Godbole said.

MISO’s interconnection queue currently contains 554 projects totaling 92.5 GW, including 239 additions last month representing 40.7 GW.

“With 93 GW, everyone needs to have a very realistic expectation of when these projects are going to be able to connect,” Godbole said. “Some of these projects are not going to get built, but how many is anyone’s guess. So MISO … needs to find ways to expedite the process.”

After looking into other RTOs’ practices, MISO found that ERCOT, ISO-NE, NYISO, PJM and SPP require 100% of site control either at entry or before the start of the system impact study, Godbole said.

“We said OK, if interconnection customers in other RTOs are OK with that, they should be OK with that in” MISO’s, he said. “We’ve looked at this from all angles.”

Some stakeholders said that state regulatory requirements can sometimes prevent customers from acquiring site control so early in the process. Godbole responded that in those cases customers would have to provide evidence that regulators are obstructing site control.

Godbole proposed a phased-in approach to requiring site control, with projects already in the queue but not yet studied required to secure 100% of site control requirements by the first decision point in the first phase of the DPP. All other projects would be required to demonstrate an increasing percentage of site control based on their progress.

Studies Reduction

To further accelerate the queue process, MISO is also proposing to eliminate its transient-stability, short-circuit and affected-system studies from the first phase of the DPP.

Removing the early, more uncertain iterations of those studies will result in quicker turnaround times for the first phase of DPP analysis, Godbole said.

In response to the concerns of some stakeholders that affected-system and transient-stability analyses were necessary earlier in the queue to determine the viability of a project, Godbole said that customers could hire an external consultant to conduct first versions of the analyses and pointed out that all three studies will still occur in the DPP’s second and third phases.

Godbole noted that MISO is currently holding monthly meetings with SPP and PJM to improve the affected-system study process, but he added that by removing the first affected-system study, MISO planners will have more time to devote to the more significant second and third studies.

“It’s not SPP, PJM or MISO’s fault. What’s happening is we have entities with three cycles that are just bombarding our affected systems with analyses,” Godbole said. “There are so many studies happening at the same time. If we keep requesting studies, we’re never going to finish. It’s going to be really tough to get those projects interconnected.”

Removing affected-system studies from the first phase of the DPP will reduce the potential for overlap among studies and eliminate at least 10 early affected-system studies in the next 12 months.

MISO said its West region — covering Iowa, Minnesota, part of Wisconsin and the Dakotas — has experienced one to two months of delays alone from conducting phase 1 affected-system studies.

“Look at the West region. It’s almost 200 projects alone,” Godbole said.

He asked stakeholders to submit feedback about the proposals by May 30, before MISO moves the recommendations to the June 13 Planning Advisory Committee meeting for an additional month of discussion. RTO staff hope to file Tariff changes with FERC by July or August.

While MISO is not seeking consensus to move forward, it will consider comments that could improve the proposal, Godbole said.

“Believe me, my phone does not stop ringing with customers concerned that they won’t get [production tax credits] in time. Something has got to give. And these are the … things that we think can have the most impact in a short amount of time. But it’s doesn’t stop here. We’re going to keep working [on the queue],” he said.

He added that future queue changes may entail moving milestone payments to a cash-only system, removing the option for customers provide a letter of credit. While MISO is not ready to propose the change, Godbole said the multimillion dollar companies that enter the queue should have no trouble providing milestone fees in cash. Some stakeholders said that although the monetary risk was the same, it’s more difficult going through the process of getting cash.

EDF Renewable Energy, which had petitioned FERC to order MISO to redesign the three-stage queue, said it supported the changes and expected them to help reduce delays, but the company thinks more needs to be done, including increasing milestone payments to deter speculative projects.

2 Projects, 1 POI

The IPTF is also collecting stakeholder feedback on a possible plan to loosen MISO’s one project/one point of interconnection policy in order to allow two projects with separate owners to connect at the same point of interconnection.

MISO manager Arash Ghodsian said the RTO would only move ahead with proposing the change if it doesn’t threaten reliability or present new delays in the interconnection queue.

Ghodsian said MISO has recently experienced an uptick in interest from customers wishing to connect multiple projects at a single point of interconnection.

Northern Indiana Public Service Co.’s Brett Furuness said he would appreciate future discussion on the topic because NIPSCO fields multiple interconnection requests at a single substation.