By Amanda Durish Cook

CARMEL, Ind. — MISO staff say the RTO is mostly up to speed with a recent FERC order aimed at increasing the transparency of the generator interconnection processes — but they continue to tackle issues related an overbooked queue.

Compliance with Order 845 largely involves inserting FERC-directed language and existing Business Practices Manual text into the Tariff, MISO said last week.

“Most of the compliance directives we already comply with in some shape or form,” counsel Chris Supino told stakeholders at a July 17 Interconnection Process Task Force meeting. He said MISO is “early” in its compliance plan and plans to share draft Tariff language in September.

“Most of these are fairly administrative; some we’ll have some more discussion around,” Supino said.

FERC issued the order in April, setting out 10 new rules intended to increase the transparency and timeliness of RTO generator interconnection processes. (See FERC Order Seeks to Reduce Time, Uncertainty on Interconnections.) MISO in mid-May joined an ISO/RTO Council request to extend the original Aug. 7 filing deadline, which FERC pushed out to Nov. 5.

Supino said most of MISO’s remaining work will focus on a new requirement to post quarterly summary statistics on its queue, including the number of withdrawn projects, completed projects and delayed projects; the proportion of studies completed by Tariff deadlines; and average study completion time.

MISO is now also obligated to file informational reports for four consecutive quarters if it misses deadlines on 25% or more queue studies during two consecutive quarters. The reports must explain reasons for the delays, steps taken to minimize them and the total number of employee and consultant hours spent on studies during the quarter.

Supino told stakeholders:

• MISO generally complies with a directive to list specific study processes and assumptions because it already posts study models for review on its nonpublic Open Access Same-Time Information System. It will examine how the directive interacts with its existing nondisclosure agreements and whether it should issue more NDAs in order to share the models with a broader group.
• The RTO will revise its generator interconnection agreement to give customers the option to build interconnection facilities and standalone network upgrades regardless of whether a transmission owner can meet a customer’s proposed in-service dates. It will also likely leverage its existing alternative dispute resolution language used for settlements to apply to members’ queue disputes.
• MISO’s net zero interconnection option should cover a directive to allow customers to utilize or transfer surplus interconnection service at existing generating facilities. Net zero permits customers to transfer existing interconnection rights to a new generator at the existing point of interconnection, provided the total interconnection does not exceed the original service limit granted in the interconnection queue.
• MISO will revise procedures to allow interconnection customers to request service lower than their generating facility capacity.
• The Tariff will be updated to include a definition of permissible technological advancements to generators that it can accommodate without a change being considered a material change, something FERC has left up to the RTOs. Instead of listing every permutation of acceptable changes, MISO will instead develop a standard to study changes.

Further GIP Alterations

Meanwhile, MISO is once again tinkering with its proposal to make generation owners more accountable for site control earlier in the interconnection queue.

MISO is now proposing to require that interconnection customers have 90% site control at the time of application based on a per acre format, with 50 acres/MW for wind generation, 5 acres/MW for solar, 1 acre/MW for battery storage and a flat 50 acres for conventional generation. All generation types must provide a detailed site map showing turbine layout. All generators would be required to demonstrate 100% site control by the second decision point of the queue.

Apex Clean Energy’s Swaraj Jammalamadaka asked whether it is fair to require generation developers to hold that amount of land especially if MISO’s queue studies become delayed.

“It’s not a bad thing to have site control, but is this reasonable?” he asked.

WEC Energy Group’s Chris Plante also questioned whether the flat 50-acre requirement for conventional units was a reasonable standard. Neil Shah, MISO manager of resource interconnection, said the requirement was based on SPP standards, but staff are open to stakeholder suggestions.

MISO last month softened its original stance that developers should provide evidence of 100% site control before their projects can enter the queue and unveiled a plan to increase the deposit due upon entry from the current $100,000 to anywhere between $500,000 and $2 million in cash, depending on project size. (See “MISO Softens Site Control Requirements in Queue Streamline,” MISO Planning Advisory Committee Briefs: June 13, 2018.) Now, the cash deposit option will only apply to projects that demonstrate regulatory restrictions to procuring site control.

MISO also still plans to remove its dynamic stability, short-circuit and affected-system analyses from the first phase of the definitive planning phase. Staff said the revisions are needed because the overbooked queue currently contains almost 93 GW of prospective generation.

“It’s in a glut, or it’s clogged, and everyone, MISO included, needs to do something,” Shah said.

Revised Milestones

MISO also plans to revise the queue’s existing milestone payment and refund structure to include a percentage of upgrades identified in affected-system studies and introduce more monetary risk for customers who keep unprepared projects in the queue.

The RTO plans to keep its current format of a $4,000/MW initial payment upon entering the DPP with two subsequent milestone payments based on a percentage of upgrade costs. However, MISO now proposes to introduce upgrade costs found in affected-system studies that occur during the phase two system impact study. The third milestone payment will now consist of 10% of necessary network upgrades and another 10% of costs associated with needed upgrades uncovered in the affected-system study. The two combined percentages are a departure from MISO’s existing third milestone payment of a flat 20% of network upgrades.

Multiple stakeholders said MISO’s proposal will make milestone payments more burdensome and riskier to stakeholders by adding the affected studies element.

Jammalamadaka pointed out that MISO cannot control the outcome of affected system studies, which to date have shown inconsistent findings.

“That more money should be a percentage of something that’s predictable,” Jammalamadaka said.

Milestone refunds will also be slightly altered under the plan. MISO will offer to refund 50% (instead of the current 100% ) of the second and third milestone payments if a project opts to withdraw at the corresponding decision points. Projects that do not elect to withdraw at a decision point risk losing their entire milestone payment even if they fail to complete a GIA.

Shah said none of the refund changes will affect the penalty-free withdrawal options that MISO built into its queue overhaul last year. Penalty-free withdrawals are allowed in MISO if network upgrade costs increase too dramatically from one phase to another in the DPP.

“We want to make sure the new rules accomplish the goal of moving projects and incentivize the not-ready projects to get out as early as possible and potentially not even enter the queue,” Shah said. “We want ready projects to progress through the process. We want non-ready projects to drop out as soon as possible. This is our intent with this proposal, and we want to process the queue as quickly as possible.”

“We’re not changing too many things here,” said MISO Resource Utilization Director Vikram Godbole. “If you’re not willing to put money up for your project, maybe you don’t belong in the [definitive planning phase], I’m sorry to say. We’re designing a process for real and ready projects.” Godbole added it would be impossible to eradicate all speculative projects from the queue.

Shah said MISO hopes to file the new queue milestone details by the latter half of September.

Some stakeholders indicated that they might contest the filing with FERC.

MISO’s Patrick Brown reminded stakeholders that the RTO will collect two more rounds of feedback on the proposal, including a discussion before the Planning Advisory Committee.

“This is not set in stone. This is wet cement here. I think it’s a little premature to talk about contesting the filing,” he said.

Brown pointed out that MISO estimates it currently has a 20% completion rate of prospective projects that enter the queue. He said MISO is trying to “thin the herd to the most viable projects” and said he hopes the RTO can achieve a 50% completion rate of queue entrants in the future.