By Amanda Durish Cook

CARMEL, Ind. — MISO will this month take a second shot at a FERC filing that would change its generator interconnection fee structure and require customers to secure locations for projects earlier in the queue.

The commission in March rejected a plan to impose more stringent site control requirements and increase milestone payments for interconnection customers, ruling that the RTO didn’t adequately demonstrate its proposals were reasonable and not unduly discriminatory. But it did agree that more stringent site control requirements and higher milestones could help reduce speculative and duplicative projects. (See MISO Promises Refile on Stricter Queue Requirements.)

This time around, MISO will not make changes to its first milestone payment, which would remain $4,000/MW instead of becoming a variable cost representing 10% of the average network upgrade cost from the last three definitive planning phase (DPP) cycles. FERC said the RTO’s percentage proposal would have resulted in inconsistent payment amounts.

However, the new plan will add a refund mechanism to the total milestone fees imposed on a customer. The “true down” feature will cap total milestones at 20% of a project’s network upgrade cost, with any excess payment refunded back to interconnection customers after a project clears the second decision point, roughly 250 days into the queue.

Like MISO’s first filing, 50% of milestone fees are considered at risk of not being refunded if they’re needed to help defray network upgrade costs should a project withdraw at the first decision point, about 180 days into the queue. At the second decision point, the percentage of at-risk fees drops to 25%. The RTO currently considers all milestone fees at risk of acquisition to help pay for promised system upgrades at both decision points.

MISO will request an Oct. 1 effective date in its new filing, Manager of Resource Interconnection Arash Ghodsian said during a meeting of the Interconnection Process Working Group on Tuesday.

“We understand that the process is working as is … but we’re looking to fine-tune. The goal is to provide the highest amount of certainty for projects coming through the queue,” Ghodsian said.

He said the new filing will occur within the month. “Exact date TBD. But we’re shooting for the near future. Soon.”

Multi-project Sites

MISO is also proposing to amend the Tariff to allow different fuel types and multiple generation projects to share the same site. The RTO said its new proposal will allow “multiple proposal submissions provided they are concurrently viable.”

FERC had said MISO’s earlier requirement that project owners demonstrate “exclusive use” site control conflicted with a Tariff section that allows interconnection customers to submit “multiple interconnection requests for a single site” and a policy that requires customers to submit separate requests for generating units that use multiple fuel sources.

MISO will propose to require all projects sharing a location to identify each other in their respective interconnection requests and provide a common diagram of land usage. It would then analyze whether all the projects can be developed on the same parcel of land.

Site Maps vs. Secured Acreage

Stakeholders argued that interconnection customers’ responsibility to demonstrate an acreage-per-megawatt minimum can be done without providing a site plan map. MISO would require customers provide a location map as part of site control 90 days prior to the start of planning studies.

Some stakeholders still contended that an acre-per-megawatt demonstration and a project site map are two different requirements. Coming up with a site map is an administrative burden, they said.

“I just don’t see how you demonstrate site control without providing a map,” responded Paul Muncy, of MISO’s transmission access planning division.

Mike Blackwell, with MISO’s legal staff, said he didn’t see how a site plan map amounted to an administrative burden because any prospective project applying to the queue should at least already have a location map or parcels for lease options.

Ghodsian said interconnection customers should be prepared to submit an approximate project layout, even if the location changes from the final site control demonstration due at the time of signing the generator interconnection agreement.

“Initially what we’re asking is, ‘Do you have enough land for your project?’ … I don’t think this is that burdensome. If your project is ready, you should be able to put land on a site map for us,” Ghodsian said.

Other stakeholders pointed out that the queue takes three years to complete, and providing a facility site map so early in the process all but guarantees location changes.

Ghodsian said early site maps will help MISO determine whether multiple projects are proposing to develop on the same property. Maps help weed out site overlap instances later in the queue, he said.

Stakeholders also questioned MISO’s proposal that interconnection customers provide a full demonstration of site control prior to entering the DPP, pointing out that two years ago, FERC deemed sufficient a 75% demonstration of site control at the time of interconnection application.

Ghodsian said the 100% site control requirement was not up for renegotiation in the refiling. He said the new proposal will stick to the same principles as the original but take FERC guidance into account.

MISO Resource Interconnection Planning Manager Neil Shah said the changes are as important as ever, given that the RTO received 45 GW of new project requests this spring, bringing the queue to more than 100 GW.

“Everybody involved in that process knows that not all are going to go through,” Shah told Planning Advisory Committee members in June. “In short, the urgency is about processing the projects in the queue as quickly as possible.”

MISO’s current generator interconnection queue includes 642 prospective projects totaling 100.6 GW.

Except for its western region, MISO will begin processing the slate of projects received in April in October or November. Because of the large number of interconnection requests in the west, the RTO will begin work on those projects in August.

MISO has negotiated more than 30 interconnection and construction agreements so far in 2019; the RTO projects it will negotiate upward of 130 agreements by year-end.

Other Time Savers

The RTO is also pursuing other avenues to reduce the amount of time projects spend in the interconnection process.

Queue engineer Will Buchanan said MISO will continue building DPP system models in-house after a successful trial run.

“MISO was able to save a considerable amount of time in the 2018 cycle versus past years,” Buchanan said.

Buchanan said the RTO’s handling of queue modeling will maintain a consistency it couldn’t achieve when it outsourced modeling work to third parties. The move also cut out the “months of delay” that it experienced with modeling vendors, Buchanan said.

MISO will also create an instant, online application for interconnection requests, replacing its previous print-and-return PDF form.

Finally, MISO is betting it can shave an additional 10 days off the queue by requiring the bulk of stakeholder model reviews take place prior to the kickoff of DPP cycles. It will allow 10 business days from model posting for stakeholder review and another five business days for any final review after the official start of the DPP.

Stakeholders said shortening the timeline on model review may increase the margin for error, especially in MISO’s western states, which currently account for 69 project requests alone in the DPP. But RTO staff countered that no review time would be lost, with the idea being that MISO releases models sooner so stakeholders can begin sizing them up earlier.

“If we can get the models out earlier, it gives people more time to review. … We’re trying to give you an extended period. It just doesn’t look the same as it does now,” Buchanan said.