MISO Zeroes in on Queue Overhaul Filing
MISO will take another crack at getting FERC approval for Tariff revisions intended to thin out and speed up its generator interconnection queue.

By Amanda Durish Cook

CARMEL, Ind. — MISO will soon take a second crack at getting FERC approval for Tariff revisions intended to thin out and speed up its overflowing generator interconnection queue.

The RTO is targeting a refiling of the rule changes by early October, a few months later than originally anticipated. (See MISO Makes Second Attempt at More Rigorous Queue.)

The commission in March rejected the RTO’s plan to impose more stringent site control requirements and increase milestone payments for interconnection customers, but it agreed the changes would reduce speculative and duplicative projects. (See MISO Promises Refile on Stricter Queue Requirements.)

MISO
Neil Shah, MISO | © RTO Insider

Speaking Wednesday at a Planning Advisory Committee meeting, Resource Interconnection Planning Manager Neil Shah made clear that the proposal is no longer up for debate. He began his presentation on the plan with an anecdote about a fixed-price, no-haggle experience at a car dealership.

“So, me, in front of you, I feel like that” car salesperson, he joked.

Shah said MISO’s queue is in dire need of the firmer site control requirements and milestone fees outlined in the plan, adding that a large volume of unready projects translates into inflated costs and cost volatility for other queued projects. The queue now includes 590 projects totaling about 92 GW after hovering around 100 GW for most of this year. In the last three years, about 800 projects comprising about 120 GW have entered the queue.

“We’ve seen projects with power purchase agreements, projects with provisional [generator interconnection agreements] forced to withdraw because of high costs,” he said.

Shah pointed to the February 2017 cycle of projects entering the queue as an example. Of 27 projects at 3.4 GW joining the queue, only two at 250 MW cleared. As a result, the MISO system went from requiring an estimated $3.4 billion in network upgrades to not needing a single one.

MISO
MISO interconnection queue September 2019 | MISO

While the penalty-free “off-ramps” incorporated into the queue in 2017 are working as intended, MISO still needs a means to discourage unprepared project owners from prematurely lining up for interconnection in the first place, Shah said.

“It still needs adjustment up front,” he said.

MISO’s proposal would require developers of proposed generating facilities to demonstrate site control 90 days before a project enters the first phase of the three-phase definitive planning phase (DPP). It would also eliminate the RTO’s current practice of accepting a $100,000 deposit in lieu of proof of site control.

The refiled plan will no longer seek changes to the queue’s first milestone payment, which will remain $4,000/MW instead of becoming a variable cost representing 10% of the average network upgrade costs from the last three DPP cycles. The new plan will also add a refund mechanism to the total milestone fees imposed on a customer. The “true down” feature would 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 220 days into the queue.

As with MISO’s first filing, 50% of milestone fees would be considered at risk of not being refunded if they’re needed to help defray network upgrade costs should a project withdraw.

Additionally, MISO will now allow different fuel types and multiple generation projects to share the same site, scrapping the first proposal’s requirement that project owners show exclusive use of land.

GenerationMISO Planning Advisory Committee (PAC)

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